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TMI Blog2024 (8) TMI 1531X X X X Extracts X X X X X X X X Extracts X X X X ..... by the assessee emanates from separate orders of ld. CIT(A)- Patna-3 dated and assessment years as mentioned therein as per the grounds of appeal on record. 2. At the time of hearing the parties herein submitted that the facts and circumstances in all these appeals are similar and identical including the issues involved in these appeals. Having heard the submissions, all these matters are heard ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3 (Bom.) considered this very issue. Answering the question in affirmative, the full bench held that a defect in notice of not striking the inappropriate words vitiates the penalty even though the AO had properly recorded the satisfaction for imposition of penalty in his order u/s143 (3) of the Act. In another judgment, the Hon'ble Bombay High Court in Pr. CIT vs. Golden Peace Hotels and Resor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bad in law. This view of the Hon'ble Karnataka High Court was upheld by the Hon'ble Apex Court whereby the SLP filed by the Department was dismissed in CIT vs. SSA Emeralds Meadows (2016 )242 taxmann 180 (S.C). 6. We must reiterate and we feel appropriate in this context of adjudication also to revisit the classic decision of Hon'ble Karnataka High Court in CIT & Anr. vs. Manjunatha C ..... X X X X Extracts X X X X X X X X Extracts X X X X
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