2016 (3) TMI 533

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....facts and circumstances of the case the Ld. CIT(A) grossly erred in sustaining the penalty of Rs. 5,28,365/- u/s. 271(1)(c) of the Income Tax Act imposed by the Ld AO. 3. That on the facts and circumstances of the case the Ld. CIT(A) grossly erred in not providing any meaningful and effective opportunity to the assessee and passing the order against the principal of natural justice 4. That the appellant crave leave to take additional ground or grounds of appeal or to alter or vary any or all the grounds of appeal before or at the time of bearing of the appeal. 3. The assessee is a partnership firm carrying on the business of manufacturing, sale and purchase of electrical goods such as Electrical Motors, Starters, Electrical Meter, MCB an....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... Rules. During the course of penalty proceedings, the assessee submitted before the Assessing Officer that it had voluntarily offered the amount of Rs. 17,09,920/- for disallowance under Rule 8D read with Section 14A out of the expenses actually incurred by the assessee. Hence the assessee has neither concealed the particulars of such income. The assessee has maintained proper books of accounts in the normal course of business. These books of accounts were subject to tax audit by an independent Chartered Accountant. The audited balance sheet, P & L account, audit report and Form 3CD were duly filed during the assessment proceedings. No defect or deficiency was found or pointed out by the Assessing Officer in the books of account or in other....