2023 (5) TMI 465

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....l by the assessee is directed against the order passed by the CIT(A)-II, Nashik on 19-09-2011 confirming penalty of Rs.99,329/- imposed by the Assessing Officer (AO) u/s.271(1)(c) of the Income-tax Act, 1961 (hereinafter also called 'the Act'). 2. It is a recalled matter inasmuch as the earlier ex parte order passed by the Tribunal on 31-12-2015 was subsequently recalled vide its later order date....

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.... seen that there is only one income of Rs.3.00 lakh, which has been considered for imposition of penalty u/s.271(1)(c) of the Act. Notice u/s.274 r.w.s.271(1)(c) of the Act was issued on 26-12-2008, whose copy has been placed on record. On perusal of such notice, it is seen that the AO proposed to impose penalty on both the limbs namely; "....you have concealed the particulars of your income or fu....