2019 (3) TMI 84

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....evenue : Ms. Deepika Mittal, CIT(DR) ORDER PER BENCH: These four appeals are filed by the assessee and challenge the confirmation of imposition of penalty imposed u/s 271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') for the captioned for assessment years as under:- (i) Assessment year 2003-04 - Penalty of Rs. 17,89,20,000/- (ii) Assessment yea....

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....glani were seized and his statement was recorded u/s 132(4) of the Act. Fresh assessments were completed u/s 153A of the Act in respect of all the captioned years and penalty proceedings u/s 271(1)(c) of the Act were also initiated for all the four years. The assessee's appeals in the quantum assessments were dismissed by the Ld. CIT (Appeals). However, the assessee's appeals before the ITAT were ....

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....eleted by the ITAT, the impugned penalties did not survive. 4.0 The Ld. CIT-DR supported the orders of the lower authorities but fairly accepted that the quantum proceedings had been settled by the Tribunal in favour of the assessee. 5.0 Accordingly, in view of the fact that the Tribunal has held the assessment proceedings u/s 153A of the Act as being void ab initio and invalid and has also ....