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2019 (4) TMI 951

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....eal on 12.12.2017 against which the appeal was filed on 15.03.2018 with a delay of 98 days. The assessee filed condonation petition stating that his wife was undergoing medical treatment for uterus cancer and he has to attend his wife for various medical consultations and treatment, therefore, the appeal could not be filed in time, hence requested to condone the delay. We have heard both the parties and convinced that there is a reasonable cause for delay in filing the appeal, accordingly, the delay is condoned. 3. In this case, the assessee filed the return of income declaring total income of Rs. 13,17,360/- and the assessment was completed u/s 143(3) on total income of Rs. 33,33,300/-. During the assessment proceedings, the AO made the ....

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....tion of facts or need further investigations. Therefore, after hearing both the parties, the additional ground raised by the assessee is admitted. 6. We have gone through the notice issued by the AO dated 10.05.2012 which is reproduced hereunder : 6.1. In the said notice, the AO did not strike off irrelevant column and made known to the assessee the specific charge for initiating the proceedings u/s 271(1)(c) of the Act, whether it is for concealment of income or for furnishing of inaccurate particulars. The assessment order is also silent on the initiation of proceedings, whether it is for concealment of income or for furnishing of inaccurate particulars of income. It is settled issue by Hon'ble High Court of Andhra Pradesh in the case P....