2021 (11) TMI 310

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.... : Sandeep Gosain, JM Both these appeals have been filed by the assessee against the separate orders of the ld. CIT(A)-3, Jaipur both dated 27/12/2018 for the A.Y. 2011-12. 2. The hearing of the appeal was concluded through video conference in view of the prevailing situation of Covid-19 Pandemic. 3. Common issues are involved in both these appeals, therefore, for the sake of convenience ....

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....er. 3. Under The facts and circumstance, the imposition of penalty for a sum of Rs. 340000 u/s. 271D of the Act is bad in law and must be deleted. 4. That on facts and law, the initiation of proceeding U/s. 271D are time barred, invalid and void ab initio. 5. The assessee may crave to amend, alter, modify or raise any other ground of appeal." 5. At the time of hearing....

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....s order that initially the case was fixed for hearing on 09/08/2018, 18/09/2018, 14/11/2018 and the ld. CIT(A) issued notice fixing the case for hearing on 26/12/2018 by issuing a letter and stated that "On verification of record, it is found that you have not filed e-appeal. The I.T. Rule 45(1) amended from 01/03/2016 but you have not filed the e-appeal. Therefore, you are requested to file an e-....

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....he facts and circumstances of the case and in the interest of justice, we decide to give one more opportunity of hearing to the assessee and remand the matter back to the record of the ld. CIT(A) for deciding the issue afresh on merits after giving an opportunity of hearing to the assessee subject to cost of Rs. 2,000/- to be paid by the assessee in the account of Prime Minister's National Rel....