2023 (4) TMI 750

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....Present:   For the Appellant : Mr. Divya Suri, Advocate with Ms. Sameeksha Gupta, Advocate. For the Respondents : Mr. Rishabh Kapoor, Advocate. Ritu Bahri, J. This order shall dispose of two income tax appeals i.e. ITA No. 12 of 2003 and ITA No. 13 of 2003 as the issue involved in both the appeals is identical. For the sake of brevity, facts are being extracted from ITA-12-2003. ....

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....ee on 29.10.1995. The assessee filed reply vide letter dated 31.10.1995 with reference to default mentioned under Section 273(2)(aa) and the same was duly taken into account while imposing the penalty. The Tribunal observed that Section mentioned in the assessment order of the first notice issued under Section 273(2)(a) does not vitiate the penalty proceedings and invalidate the penalty order as t....