2019 (2) TMI 1326

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.... PER R.K. PANDA, AM: 1. ITA No.1717/Del/2015 filed by the assessee is directed against the order dated 18.02.2014 of the CIT(A)-XVII, New Delhi relating to A. Y. 2008-09. ITA No.3883/Del/2015 filed by the assessee is directed against the order dated 28.02.2018 of the CIT(A)-XVI, New Delhi relating to A. Y. 2008-09. For the sake of convenience these appeals were heard together and are being dis....

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....e bench to the ground No.2 of the appeal which reads as under :- 2. That the Ld. ITO has erred in law as much as on the facts of the case in imposing the impugned penalty of Rs. 4,27,770/- u/s 271 (1) (c) of the IT Act for the alleged concealment of income by way of furnishing alleged inaccurate particulars of its income. He has failed to appreciate that from either of two, only one can b....