2023 (9) TMI 1034

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....umit Lalchandhani & Sh. Shivam Yadav, Adv. For the Revenue : Sh. Kanv Bali, Sr. DR ORDER PER ANUBHAV SHARMA, JM: Heard and perused the record. 2. The issues in the appeals have common background in the assessment orders and impugned penalty orders therefore are taken up together for adjudication. The appeals in ITA no. 895 to 897/Del/2023 for A.Y. 2014-15 to 2016-17 and in ITA no. 9....

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....at in all the appeals thus, penalty orders have been passed without application of mind as the orders do not disclose as to which notice was not complied with. It was submitted that the assessments are completed u/s 153(C) and not u/s 144 as such there cannot be any penalty for non-compliances and reliance in this regard has been primarily placed on the judgment of this Bench in the case of Jai Ku....

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.... do not show that if at the time of assessment. Ld. AO had made observation as to which specific document or information sought was not supplied. It appears from the penalty orders that the dispute was with regard to some external hard disc which was sought to be produced but was not produced by the assessee on the basis that it was not readable or corrupt and on that basis the AO issued notice at....