2023 (9) TMI 738

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....of the Income-tax Act, 1961 [for short 'the Act'], which ascended out of respective penalty orders of the Asstt. Commissioner of Income Tax, Circle-1(1), Panaji, Goa ['AO' hereinafter] for assessment year ['AY' hereinafter] 2009-10 & 2010-11. 2. Since identical facts and similar issue is involved in this bunch of eight appeals, at the convenience and request of both the parties hereto, we have heard these matters together for a common and consolidated order taking ITA No. 97/PAN/2019 as lead case. Resultantly our adjudication laid in succeeding paragraphs hereinafter shall mutatis-mutandis shall apply to the ITA No. 98/PAN/2019, ITA No's. 101 & 102/PAN/2019, ITA No's.107 & 108/PAN/2019 and ITA No's.111 & 112/PAN/2019. 3. The brief fac....

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....circumstances of the case, the Ld. CIT(A) ignored the fact that the Hon'ble ITAT Panaji Bench vide its order in ITA No. 3 to 27/PNJ/2015 & ITA No. 413 dated 02.12.2016 upheld the addition made by the Assessing Officer on deemed dividend. 4. On facts and in circumstances of the case, the Ld. CIT(A) erred in not appreciating the fact that the was proper recording of reasons for initiation of penalty u/s. 271(1)(C) in the body of the assessment order. 5. For the above grounds and any additional grounds that may be agitated during the course of t hearing it is prayed that the order of the Ld. CIT(A)-1, Panaji may be quashed and that of the restored." 4. The controversy under the present appeal lies in a narrow compass a....