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2022 (12) TMI 1406

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..... the A.O. We are of the opinion that the present penalty proceedings and penalty order made thereon deserves to be deleted. Accordingly, the penalty order passed in the years under consideration is hereby deleted. Appeals filed by the assessee are allowed. - I.T.A. No. 7793/Del/2017, I.T.A. No. 7794/Del/2017, I.T.A. No. 7795/Del/2017, I.T.A. No. 7796/Del/2017 - - - Dated:- 16-12-2022 - B. R.R. .....

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..... se the learned CIT(A) has erred both on facts and in law in passing the order without giving assessee a proper and adequate opportunity of being heard in violation of principle of natural justice. 3. On the facts and circumstances of the case, learned CIT(A) has erred both on facts and in law in rejecting the contention of the assessee that the AO has erred both on facts and in law in going .....

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..... of the case, the learned CIT(A) has erred both on facts and in law in confirming the penalty without giving any finding as to the merits of the case on concealment of income as well as furnishing of inaccurate particulars of income. 7. On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in ignoring the fact that the penalty proceedings are indepe .....

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..... or the assessee submitted that the assessee had approached this Tribunal by challenging the addition made by the A.O. which was sustained by the CIT(A) for the years under consideration and vide order dated 29/04/2022 in ITA No. 1805/Del/2017 (A.Y 2006-07), ITA No. 1806/Del/2017 (A.Y 2007-08), ITA No. 1807/Del/2017 (A.Y 2008-09) ITA No. 1808/Del/2017 (A.Y 2009-10), the Tribunal has deleted the a .....

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