2016 (6) TMI 1382

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....e kindly be quashed. 2. The impugned penalty order u/s 271(1)(c) of the Act is barred by limitation hence, please be quashed. 3. Rs. 1,49,160/-: the ld. CIT (A) erred in law as well as on the facts of the case in confirming the impugned penalty u/s 271(1)(c) of the Act of Rs. 1,49,160/-. The penalty so imposed & confirmed being totally contrary to the provisions f law and facts kindly be deleted in full. 4. The appellant prays your honour indulgences to add, amend or alter of or any of the grounds of the appeal on or before the date of hearing. 2. At the outset, ld. Counsel for the assessee submitted that he does not wish to press Ground No. 2 of the appeal. On this, the ld. D/R stated that he has no objection. Accordingly ground....

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....er passed under section 271(1)(c) of the Act. The ld. D/R reiterated the submissions as are made in the written submission filed on 07.06.2016. 4.2. In re-joinder, the ld. Counsel for the assessee reiterated the submission as are made in the written submission dated 6th June, 2016. 4.3. We have heard the rival contentions, perused the material on record and gone through the orders of the authorities below. During the course of hearing, the ld. D/R has conceded the fact that in the notice dated 30th November, 2009 on printed form wherein the words ' concealed the particulars of your income or furnished inaccurate particulars of such income' is printed and tick marked by the AO. Therefore, when the notice was issued, there was no specific....