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2023 (3) TMI 1305

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....l filed by the Assessee against the order of the Ld. CIT(A)-3, Ludhiana dt. 18/01/2019 pertaining to A.Y. 2007-08 challenging the confirmation of penalty under section 271(1)(c) of the Act. 2. At the outset it is noted that there is a delay of 10 days in filing the present appeal. Considering the submissions made by the Ld. AR and after hearing the Ld. DR, the delay is hereby condoned and the app....

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....e appeared on behalf of the assessee and the AO accordingly proceeded and passed the penalty order under section 271(1)(c) on 22/09/2015 holding that the assessee in default of making concealment of income to the extent of Rs. 28,84,000/-. 5. Against the penalty order, the assessee moved in appeal before the Ld. CIT(A) wherein again, there was non-appearance and non-compliance on the part of the ....

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....alty under section 271(1)(c) of the Act. It was accordingly submitted that where the addition in the quantum proceedings stands deleted, then the very foundation for levy of penalty does not exist and in light of the same, the penalty so levied and confirmed by the Ld. CIT(A) may be set aside. 8. Per contra, the Ld. DR fairly agreed that the order of the Ld. CIT(A), Panchkula deleting the quantum....

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....isclosed sources as assessee did not participate in assessment proceedings and explain the sources of cash deposits made in his bank account of equivalent amount. During appellate proceedings the appellant has explained with satisfactory documentary evidences that he received Rs.26,02,500/- on account of sale of 20 Bigha 16 Biswa rural agricultural land at Haryoli and has submitted copy of sale de....