2022 (5) TMI 1148

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....r.D. R; ORDER PER CHANDRA MOHAN GARG, J. M. : The aforesaid appeal has been filed by the assessee against the impugned order dated 21.11.2019, passed by the ld. Commissioner of Income Tax (Appeals)-XXXVI, New Delhi, [hereinafter referred to as CIT (Appeals)] under Section 271(1)(c) of the Income Tax Act, 1961 (the Act) for the assessment year 2014-15. 2. The assessee has challenged pen....

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....ticulars of his income whereas in the penalty order dated 31.03.2019 under Section 271(1)(c) of the Act in the concluding para 4 it has imposed impugned penalty by alleging that the penalty is being imposed for furnishing of inaccurate particulars of income. Therefore, in view of defective penalty notice and various judgements including the judgement of Hon'ble Delhi High Court in the case of Pr. ....

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....limb of Section 271(1) (c) the penalty proceedings had been initiated under i.e. whether for concealment of particulars of income or for furnishing of inaccurate particulars of income. The Karnataka High Court had followed the above judgment in the subsequent order in Commissioner of Income Tax v. SSA's Emerald Meadows (2016) 73 Taxman.com 241 (Kar), the appeal against which was dismissed by the S....