Mechanical Penalty Imposition u/s 271(1)(c) Deemed Irreparable by Appellate Authority Due to Procedural Error.

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....Penalty u/s 271(1)(c) - addition u/s 68 - Penalty has been levied in a mechanical manner without application of mind. In our view, this is a serious mistake in the penalty order which is incurable at this stage - by restoring the penalty to the file of the Ld. CIT(A), the appellate authority can not cure the defect/mistake which has been committed by the AO in the penalty order passed under section 271(1)(c) - AT....