2021 (3) TMI 458

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....g penalty of Rs. 10,000.00 is bad on both on fact and in law. 2. That in any view of the matter the assessee has made necessary compliance on each and every date and there was no bona fide intention of not co-operating with the department but under unavoidable circumstances on some date the assessee was not aware of the notices hence penalty imposed is highly unjustified. 3. That in any view of the matter in past no penalty was ever imposed nor there was any non compliance hence penalty imposed is highly unjustified. 4. That in any view of the matter the assessee reserves his rights to take any fresh ground of appeal before hearing of appeal." 2. The Ld. A.R. of the assessee has submitted that the assessee file....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....tted that there are several bank accounts in the joint name of the assessee and her husband. The Assessing Officer has assessed the income on account of cash deposit in the bank account in the hands of assessee as well as her husband by considering the fact of the first bank account holder. The deposit made in the bank account where the assessee is first account holder is assessed in the hand of the assessee whereas the deposit made in the bank account where the husband of the assessee is a first account holder was assessed in the hand of the assessee. The Ld. DR has further submitted that there is no dispute that the assessee has not complied with the notice issued u/s. 142(1) and therefore, the penalty u/s. 271(1)(b) of the Act is justifi....