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Penalty u/s 272A(1)(C) - wilful noncompliance to the summons u/s 131 - it is the ITO/AO who has the power to pass the penalty order and not the Add. CIT. Therefore, we hold that the Addl. CIT had no jurisdiction to pass the penalty order in the case before us.
Penalty u/s 272A(1)(C) - wilful noncompliance to the summons u/s 131 - it is the ITO/AO who has the power to pass the penalty order and not the Add. CIT. Therefore, we hold that the Addl. CIT had no jurisdiction to pass the penalty order in the case before us.
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