2021 (11) TMI 310

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.... 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 and brevity, a consolidated order is being pass....

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....nalty 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, none has appeared on behalf of the assessee. From the record, we observe that the ld....

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....018 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-appeal, otherwise your appeal filed manual will be treated as unrest." On the above date....

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.... 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 Relief Fund/Prime Minister's Care Fund within 30 days from the date of receipt of this ....