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2019 (8) TMI 1442

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....d by the assessee against the order dated 18.08.2017 of the Commissioner of Income Tax (Appeals) [hereinafter referred to as the CIT(A)]relevant to assessment year 2012-13. 2. The assessee has challenged the order of Ld. CIT(A)confirming the penalty as levied by the AO under section271(1)(c) of the Act both on merit as well as on technical issue. 3. We would like to first adjudicate the appeal o....

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....e particulars of income qua the cessation of liability whereas no penalty proceedings were initiated in respect of disallowance made under section 14A of the Act. The penalty notice dated 10.03.2015 was issued undersection 274 read with section 271(1)(c) wherein the specific charge was not stated i.e. the notice was issued in a standard format without striking off the redundant limb in the notice.....

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....ad with section 271(1)(c).We observe that the said notice was issued in a standard format without striking off the redundant or irrelevant part of the notice and the notice states that penalty has been initiated for concealing the particulars of income or for furnishing of inaccurate particulars of income. Thus the notice has been issued by the AO in a mechanical manner without application of mind....