https://www.taxtmi.com/caselaws?id=456748 ITAT Mumbai held that the second penalty notice u/s 274 was valid for imposing penalty u/s 271(1)(c) regarding disallowance of deduction u/s 10B, as the penalty was levied on the same ground on which proceedings were initiated. CIT(A) erred in deleting the penalty without considering the complete facts and the second notice. However, no penalty could be levied for transfer pricing addition as the second notice did not reference this issue and the assessee was not put to notice regarding inaccurate particulars relating to transfer pricing. The matter was remanded to CIT(A) for adjudication on merits regarding the s.10B deduction penalty. Revenue appeal was partly allowed. en-us Tue, 17 Jan 2023 00:00:00 +0530 Mon, 12 Aug 2024 20:08:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456748 ITAT Mumbai held that the second penalty notice u/s 274 was valid for imposing penalty u/s 271(1)(c) regarding disallowance of deduction u/s 10B, as the penalty was levied on the same ground on which proceedings were initiated. CIT(A) erred in deleting the penalty without considering the complete facts and the second notice. However, no penalty could be levied for transfer pricing addition as the second notice did not reference this issue and the assessee was not put to notice regarding inaccurate particulars relating to transfer pricing. The matter was remanded to CIT(A) for adjudication on merits regarding the s.10B deduction penalty. Revenue appeal was partly allowed. Case-Laws Income Tax Tue, 17 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456748