TaxTMI 
TaxTMI 
2023 (8) TMI 676
X X X X Extracts X X X X
X X X X Extracts X X X X
....gainst 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 the Act even though the Ld. AO has framed assessment ....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... 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 applicable in the case of the appellant." 3. Facts giving rise to the p....
X X X X Extracts X X X X
X X X X Extracts X X X X
....sessee 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 the assessee was having reasonable cause for non-compliance, he prayed that the i....