TMI Blog2024 (2) TMI 1200X X X X Extracts X X X X X X X X Extracts X X X X ..... essee had opted for Vivad Se Vishwas Scheme but Form No.4 could not be submitted electronically and same was submitted manually. Therefore, CIT(A) ought to have accepted the submissions of the assessee and granted relief to the assessee. Thus hold accordingly. AO is directed to give benefit of Vivad Se Vishwas Scheme to the assessee upon furnishing of the requisite documents. Grounds raised ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mpugned order passed under section 271FA of the Act, since the same was passed without giving a proper opportunity of being heard to the appellant which is against the principal of natural justice. 1.2. That the Ld. AO has grossly erred in imposing penalty under section 271FA of the Act, since the late filing of the SFT statement Online by the appellant was due to the technical problems faced ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was facing problem while filing the same online. 2. Facts giving rise to the present appeal are that the assessee is Sub- Registrar in Haryana Government, posted at Madlauda Panipat. The Assessing Officer ( AO ) initiated penalty proceedings u/s 271FA of the Income Tax Act, 1961 ( the Act ) and thereafter, imposed penalty of INR 1,01,900/- vide order dated 27.06.2019. 3. Aggrieved against ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on record and gone through the orders of the authorities below. It is stated by the Ld. Counsel for the assessee that the assessee had opted for Vivad Se Vishwas Scheme but Form No.4 could not be submitted electronically and same was submitted manually. Therefore, looking to the totality of the facts, I am of the considered view that Ld.CIT(A) ought to have accepted the submissions of the asses ..... X X X X Extracts X X X X X X X X Extracts X X X X
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