High Court Remands Case to ITAT for Lack of Independent Reasoning on Penalty u/s 271AAB(1)(c) of Income Tax Act.

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....Penalty u/s 271AAB(1)(c) - reasonable cause for the said failure - in the absence of any independent reasoning by the learned Tribunal with regard to the merits of the matter of the respondent/assessee, it will not be possible for us to test the correctness of the order passed by the learned Tribunal, more particularly, when we are to ascertain as to whether any substantial question of law arises for consideration. - Matter restored back to ITAT - HC....