2023 (8) TMI 676

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... appeal filed by the assessee is directed against the order passed by Ld.CIT(A), National faceless Appeal Centre ("NFAC") dated 21.04.2023 for the assessment year 2012-13. 2. The assessee has raised following grounds of appeal:- 1. "Without prejudice to the Ground of Appeal no. 1, the Ld. CIT (A) erred in law and facts in confirming penalty imposed of Rs 10,000/- u's 271(1)(b) of t....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....cuments. 4. Without prejudice to the Ground of Appeal no. 1, the Ld. CIT (A) erred in law and facts in confirming penalty imposed of Rs 10,000/- u/s 271(1)(b) of the Act without appreciating the facts that alleged non-compliance of notice issued u/s 142(1) of the Act dated 06.11.2019, if any was not deliberate and due to reasonable cause, therefore provisions of section 273B of the Act is....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

...., sustained the penalty. 5. Aggrieved against the order of Ld.CIT(A), the assessee preferred appeal before this Tribunal. 6. Ld. Authorized Representative ("AR") of the assessee submitted that the notice was not received by the assessee. Therefore, the assessee could not make compliance of the notice. He further contended that non-receipt of the notices was the reason for non-compliance. As ....