2018 (5) TMI 1431

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.... appeals by the assessee directed against the respective orders of the learned CIT(A) for the concerned assessment years against the levy of penalty under Section 271(1)(c) of the Income Tax Act (hereinafter "the Act") as under: - A.Y. Penalty 2005-06 Rs. 2,12,74,580/- 2006-07 Rs. 41,61,620/-   2. The assessee has also sought to raise common additional ground. The submissions in th....

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.... two charges i.e. (a] for concealing the particulars of income or (b) furnishing inaccurate particulars of income are being put against him. And if it was not so, the notice was invalid and penalty u/s. 271(1)( C) could not be levied. The Appellant states that the Additional Grounds sought to be raised now are the legal grounds which go to the root of the appeal. They also do not require any fr....

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.... to the file of learned CIT(A). The learned CIT(A) is directed to consider the additional ground and pass appropriate order on the ground so raised after giving the assessee an opportunity of being heard. 5. Since we have already remitted the additional ground which goes to the root of the matter, we are not considering the merits of the order passed by the learned CIT(A).It has been expounded by....