2020 (10) TMI 837

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....tative of both the parties through video conferencing and perused the material available on record. 3. Briefly the facts of the case are that a search and seizure operation under section 132 of the IT Act was conducted at business premises of companies of Rockland Group as well as at the residential premises of Directors of the Companies on 06.09.2011. Survey under section 133A of the I.T. Act were also conducted at various premises of group cases. The A.O. issued notices under section 153C of the I.T. Act. 1961, for the A.Ys. 2009-10 to 2011-2012 and passed the assessment orders under section 153C of the I.T. Act, 1961. In A.Y. 2012-2013 the A.O. passed the assessment order under section 143(3) of the I.T. Act. The A.O. in all the asses....

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....lled. He has relied upon Judgment of the Hon'ble Delhi High Court in the case of Pr. CIT vs., Sahara India Life Insurance Company Ltd., reported in 2019-(8)-TMI-409-Del.-HC. 5. On the other hand Ld. D.R. relied upon the Orders of the authorities below. 6. We have considered the rival submissions and perused the material on record. Learned Counsel for the Assessee referred to the show cause notices issued by A.O. before levy of the penalty Dated 20.06.2014, the same are bad in Law as it did not specify under which limb of Section 271(1)(c) of the I.T. Act the penalty proceedings had been initiated i.e., whether for concealment of particulars of income or furnishing inaccurate particulars of income. In the case of CIT vs. M/s. SSA's Eme....