TMI Blog2024 (1) TMI 310X X X X Extracts X X X X X X X X Extracts X X X X ..... in a standard format - HELD THAT:- We find that the notice was issued in a standard format, i.e. by mentioning both the limbs of penalty. In other words, it has been mentioned that the assessee has furnished inaccurate particulars of income, which is not correct position of law. In our opinion, AO has to issue the show-cause notice by mentioning the correct limb on the penalty was propose d to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1961 for A.Y. 2012-13 framed by National Faceless Assessment Centre, Delhi. 2. The legal issue raised by the assessee is that the ld. CIT(Appeals) has erred in law and on facts by upholding the penalty order passed under section 271(1)(c) of the Income Tax Act, which was passed after issuing invalid show-cause notice in which the relevant limb for imposing penalty was not indicated. 3. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 02.02.2022 passed under section 271(1)(c) of the Act, which was also affirmed by the ld. CIT(Appeals). 4. The ld. Counsel for the assessee vehemently submitted before us that the penalty has been imposed by the ld. Assessing Officer on the addition made, which has been deleted by the ld. CIT(Appeals) nonetheless the ld.CIT(Appeals) has made the addition on some different accounts. The ld. A.R. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... es the assessee from responding on the correct charge/limb on which the penalty was imposed and, therefore, the ld. A.R. prayed that the penalty imposed by the ld. Assessing Officer be deleted. 5. On the other hand, ld. D.R. relied on the order of authorities below. 6. After hearing the rival contentions and perusing the material placed before us, we find that the notice dated 26.03.2015 was ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
