2022 (10) TMI 987

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....nt : Mr. J.P. Khaitan, Sr. Adv., Mr. Pranit Kr. Bag, Adv., Mr. Snehashis Sen, Adv., Mr. Abhishek Banerjee, Adv. And Mr. Aditya Sarkar, Adv. ORDER The Court : We have heard Mr. Soumen Bhattacharjee, learned standing Counsel for the appellant and Mr. J.P. Khaitan, learned Senior Advocate duly assisted by Mr. Pranit Kr. Bag for the respondent. There is a delay of 603 days in filing the appeal. On....

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....come Tax Appellate Tribunal erred in mechanically holding the notice for imposition of penalty as invalid, because of not striking off the "inaccurate particular of income" portion in the notice under section 274 of the Income Tax Act, 1961 for initiation of penalty proceeding U/s. 271(1)(c) ? b) Whether on the facts and in the circumstances of the case and in law, the Learned Income Tax Appella....

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.... of the decision of the Supreme Court in Pricewaterhousecoopers Pvt. Ltd. Vs. CIT, (2012) 348 ITR 306 (SC). On facts it is found that the assessee's aim to offer interest income on income tax refund was an inadvertent and bona fide error and no contumacious conduct has been established by the assessing officer. The revenue filed appeal before the Tribunal. The Tribunal after considering the correc....