2016 (9) TMI 1066

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....eferred by the revenue against the order of CIT(Appeals)-2, Bengaluru dated 27.04.2015 deleting the penalty levied u/s. 271(1)(c) of the Income-tax Act, 1961 [hereinafter referred to as "the Act"]. The assessee has filed the Cross Objections raising a preliminary objection that the CIT(Appeals) has not given any finding on the submissions of the Respondent-assessee that in light of the decision of....

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.... account of concealment of particulars of income or furnishing inaccurate particulars of such income. It was further contended that the Hon'ble jurisdictional High Court has categorically held in the case of CIT & Anr. V. Manjunatha Cotton & Ginning Factory (supra) that notice u/s. 274 of the Act should specifically state the grounds mentioned u/s. 271(1)(c) i.e., whether it is for concealment....

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....e Hon'ble jurisdictional High Court in the case of CIT & Anr. V. Manjunatha Cotton & Ginning Factory (supra) and they have laid down the parameters under which penalty u/s. 271(1)(c) of the Act has to be levied. Under clauses (p) & (q) of para 63 of the judgment, Their Lordships have held that notice u/s. 274 should specifically state the grounds mentioned in. 271(1)(c), i.e., whether it is fo....