2020 (2) TMI 1693

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....he only contention envisaged by the learned Authorized Representative that the assessee is deprived of reasonable opportunity of hearing before the assessing authority in levying the penalty and also CIT (Appeals) has confirmed the penalty. 3. The Brief facts of the case are that the assessee is engaged in the business of land development and Real estate activities and filed the Return of Income for Assessment Year 2014-15 on 26.09.2014 and subsequently the case was selected for scrutiny and Notice under Section 143(2) and 142(1) were issued. In compliance, the learned Authorized Representative appeared from time to time and furnished the details. The Assessing Officer in the course of assessment proceedings, found that the assessee has is....

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....eved by the order, the assessee has filed an appeal with the CIT(Appeals), whereas the CIT(Appeals) has confirmed the levy of penalty and dismissed the appeal. Aggrieved by the CIT (Appeal) order, the assessee has filed an appeal with the Tribunal. 4. The learned Authorized Representative at the time of hearing submitted that the penalty was levied by the Assessing Officer under the provisions of Section 271(1)(c) of the Act for concealment and inaccurate particulars furnished and further no reasonable opportunity of hearing was provided to the assessee before initiating the penalty and only one hearing was granted. Further the CIT(Appeals) has not granted sufficient time to the assessee to substantiate the case with evidence and prayed fo....