2019 (5) TMI 544

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....Yadav - Ld.DR ORDER PER MANOJ KUMAR AGGARWAL (ACCOUNTANT MEMBER) 1. Aforesaid appeal by assessee for Assessment Year [in short referred to as 'AY'] 2009-10 contest the order of Ld. Commissioner of Income-Tax (Appeals)-49, Mumbai, [in short referred to as 'CIT(A)'], Appeal No. CIT(A)-49/IT-54/2015-16 dated 22/03/2017 qua part confirmation of penalty u/s 271(1)(c). 2. Explaining the same....

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....7 wherein a direction was issued to Ld. AO to recompute the penalty on revised disallowance. Aggrieved by confirmation of penalty to that extent, the assessee is in further appeal before us. The Ld. AR submitted that confirmation of penalty even to that extent was not justified since the primary ingredients of Section 271(1)(c) would not be fulfilled so as to attract the said penalty. The Ld. DR s....