2019 (1) TMI 149

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....his appeal by the assessee pertaining to the assessment year 2009-10 is against order of the CIT(A)-II, Indore dated 18.9.2017. The assessee has raised following grounds of appeal: 1. On the facts and in the circumstances of the case, Ld. CIT(A) erred in confirming the penalty u/s 271(1)(c) of the Act. 2. Appellant reserves right to add, alter or amend any of the grounds of the appeal. 2. The....

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....essee are as under: The above referred appeal is filed against the penalty order passed u/s 271(1)(c) Which was initiated in the reassessment order made u/s 148/143(3) dated 16/02/2015. The ground for initiating referred penalty proceeding was "submission of inaccurate particulars of income" as per the reassessment order. In this matter, respectfully submitted as below : (i) Assessee is a comp....

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....t income has been Withdrawn bv the recent Finance Act 2007 01/04/2008 only. Even Ld. AO also failed to take notice of amendment While passing assessment order u/s. 143(3) even though he discussed about and allowed claim u/s. 10B, (v) Subsequently notice u/s 148 dated 28/03/2014 was issued to the assesse as exempt income of was wrongly deducted While calculating book profit u/s. 115JB. The asse....

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.... w.e.f. 1.4.2008. The reliance is placed on the judgement of the Hon'ble Delhi High Couirt rendered in the case of CIT Delhi-2 Vs. Compro Technologies P. Ltd. (2015) 55 Taxmann.com 180 (Del) and the judgement of the Hon'ble Supreme Court in the case of Price Waterhouse Coopers Pvt. Ltd. Vs. CIT (2012) 348 ITR 306 (SC). The authorities below have not accepted the explanation of the assessee....