2017 (11) TMI 1759

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....ble,   The appeal is filed by the assessee against the order dated 24/06/2016 passed by CIT(A)-3, Gurgaon. 2. The grounds of appeal are as under:- " 1. That having regard to the facts and circumstances of the case, Ld.CIT(A) has erred in law and on facts in upholding the action of Ld. A.O in imposing penalty of Rs. 41,125/- u/s 271(1)(c) and that too without assuming jurisdicti....

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....al before the CIT(A) who vide order dated 19/11/2012 deleted the additions of Rs. 10,00,000/- and confirmed the addition of Rs. 1,33,088/- stating that the assessee did not pressed for the ground No. 3 of the appeal as the issue of addition of Rs. 1,33,088/- on account of deduction claim was under section 24(b) of the Act. 5. The penalty proceedings were started u/s 271(1) (c) and the A.O impos....

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....e Assessee has also filed all the details during the regular assessment proceedings. From the notice dated 28.12.2011 produced by the Ld. AR during the hearing, it can be seen that the Assessing Officer was not sure under which provisions of Section 271 of the Income Tax Act, 1961, the assessee is liable for penalty. The issue is squarely covered by the decision of the Hon'ble Supreme Court in....