2020 (12) TMI 494

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.... This is assessee's appeal for the AY.2015-16, directed against the order of the Commissioner of Income Tax (Appeals)-1, Hyderabad, dated 16-05-2019, confirming penalty levied by the Assessing Officer (AO) u/s.271(1)(c) of the Income Tax Act [Act]. 2. The case is taken up for hearing on 24-11-2020 through video conferencing and both the parties were heard. 3. The Grounds raised by assesse....

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....he grounds, the assessee is challenging the validity of notice issued u/s.271(1)(c) of the Act, because the AO has not struck-off the irrelevant portion of the notice dt.28-12-2017 for levy of penalty u/s.271(1)(c) of the Act. He further submitted that the AO has not expressed his satisfaction either in the assessment order or in the notice u/s.274 r.w.s. 271(1)(c) of the Act for initiating the pe....

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....-parte and the CIT(A) and the AO have not mentioned any reason for initiating the penalty u/s.271(1)(c) of the Act. Further as seen from the copy of the notice issued u/s.274 r.w.s.271(1)(c) of the Act, the AO has not struck-off the irrelevant portion in the notice i.e., whether the penalty is being levied for concealment of income or for furnishing of inaccurate particulars or for both. In view o....