2022 (11) TMI 214

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....see against the order of the ID  CIT(A)-1, Bhubaneswar both 30.10.2013 in appeal no 243/11-12 & 244/11-12 against confirmation of levy of penalty u/s.271F of the Act for  the assessment year 2008-09 & 2009-10 2. It was submitted by ld AR that the assessee was in the process of collecting the copy of the seized documents. It was submitted that consequently, he assessee had not filed the ....

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....ithin 2-3 months. It was the submission that the order of the ld CIT(A) was liable to be upheld. 4. We have considered the rival submissions. The levy/confirmation of penalty is based on the facts of each case. There is no presumption that the assessee is willfully violating the law. It is an admitted fact that notice u/s.153A has been served on the assessee and the assessee is required to file t....