2022 (7) TMI 1222

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....on 271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') dated 21.04.201 for assessment year (AY) 2010-11. The assessee has raised the following grounds of appeal:- "1.On the facts and in the circumstances of the case and in law the penalty order so passed by the ld. Assessing Officer and upheld by the CIT(A) is bad-in-law as the orders so passed by the ld. Lower authorities have not considered the appellant's contention that notice u/s 274 failed to explicitly mention that penalty proceedings are being initiated for furnishing of inaccurate particulars or that for concealing particulars of income. Therefore, the order so passed on the basis of notice issued without recording proper satisfaction is bad-in-law and th....

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.... officer issued show cause notice under section 274/271 dated 06.03.2017. The assessing officer noted that no reply was filed by the assessee. The assessing officer levied the penalty @ 100% of tax sought to be evaded on the addition of Rs. 16,53,600/-. The assessing officer worked out the penalty of Rs. 4,60,537/-. Aggrieved by the levy of penalty the assessee filed appeal to Ld. CIT(A). Before Ld. CIT(A) the assessee filed detailed written submissions. The submissions of the assessee are recorded in para-5 of the impugned order. In the submissions the assessee submitted that the assessing officer has not specified the charge in the notice and has signed the notice without striking inapplicable words in the notice. The Ld. CIT(A) after con....