Penalty Order u/s 271(1)(c) Flawed Due to Lack of Separate Proceedings for Sections 143(3)/153A and 143(3)/147 Additions.

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....Penalty u/s 271(1)(c) - combined order of penalty for additions made vide order u/s 143(3) r.w.s. u/s 153A and u/s 143(3) r.w.s. 147 - AO required to initiate two penalty proceedings by issue of separate notices u/s 271(1)(c) and to pass separate penalty orders independently - there was a defect in the penalty order passed hence the same is unsustainable....