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ITAT held that no specific charge was framed against the assessee in the show-cause notice issued u/s 274 read with Section 270A for misreporting of income. While the assessment order did not specify the exact charge, the show-cause notice initiated penalty proceedings for both under-reporting and misreporting of income. However, in the penalty order, the Assessing Officer concluded it was a case of under-reporting due to misreporting of income and levied penalty u/s 270A(9)(a). ITAT decided in favour of the assessee on the ground that no clear charge was framed in the show-cause notice.
ITAT held that no specific charge was framed against the assessee in the show-cause notice issued u/s 274 read with Section 270A for misreporting of income. While the assessment order did not specify the exact charge, the show-cause notice initiated penalty proceedings for both under-reporting and misreporting of income. However, in the penalty order, the Assessing Officer concluded it was a case of under-reporting due to misreporting of income and levied penalty u/s 270A(9)(a). ITAT decided in favour of the assessee on the ground that no clear charge was framed in the show-cause notice.
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