Penalty for Noncompliance with Income Tax Summons Invalid if Issued by Additional CIT, Not ITO or AO.

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....Penalty u/s 272A(1)(C) - wilful noncompliance to the summons u/s 131 - it is the ITO/AO who has the power to pass the penalty order and not the Add. CIT. Therefore, we hold that the Addl. CIT had no jurisdiction to pass the penalty order in the case before us.....