2019 (6) TMI 89

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....ia a/w Miss Nainee N. Savla For the Revenue : Shri S.K. Jain ORDER PER SAKTIJIT DEY. J.M. The aforesaid appeal has been filed by the assessee challenging the order dated 11th December 2017, passed by the learned Commissioner (Appeals)-24, Mumbai, confirming penalty of Rs. 2,33,38,168, imposed under section 271(1)(c) of the Income Tax Act, 1961 (for short "the Act") for the assessment y....

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....aid submissions of the learned Authorised Representative. 5. We have considered rival submissions and perused the material on record. It is evident from the facts on record that in the original assessment order, the Assessing Officer made certain additions and also changed the head of income in respect of certain items of income which resulted in determination of total income at Rs. 5,97,05,484....