2023 (1) TMI 372

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..../06/2018 passed under section 271(1)(c) of the Act, for the assessment year 2014-15. 2. In its appeal, the assessee has raised following grounds:- "Ground 1- On the facts and circumstance of the case and in law, the Commissioner of Income-tax (Appeals) - 36, Mumbai (hereinafter referred to as "the Leamed CIT(A)") has erred in not considering that the notice issued under section 274 read with section 271 of the Income-tax Act, 1961 (hereinafter referred to as "the Act") is void ab initio as its violative of the principle of natural justice. It is, therefore, prayed that the notice be treated as void ab initio and the proceedings be dropped. Tax Effect - Rs.9,56,601/- Without prejudice to the ab....

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....For the year under consideration, the assessee filed its return of income on 09/07/2014, declaring a total income of Rs.2,36,890. Pursuant to the information received from the Directorate of Investigation, Kolkata, proceedings under section 147 of the Act were initiated in assessee's case. Vide order dated 11/12/2017, passed under section 143(3) r/w section 147 of the Act, the total income of the assessee was assessed at Rs.33,20,390. 5. Meanwhile, vide notice dated 11/12/2017, issued under section 274 r/w section 271(1)(c) of the Act, penalty proceedings in assessee's case were initiated. Vide order dated 28/06/2018, passed under section 271(1)(c) of the Act, a penalty of Rs.9,56,601, was levied. In further appeal against the penalty or....