2023 (10) TMI 624

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....Amit Kr. Sharma, CA For the Revenue : Shri Kanv Bali, Sr. DR ORDER PER BENCH:- The present appeals have been filed by assessee against the orders of ld. CIT(A)-29, New Delhi, dated 24.03.2023 for A.Ys. 2010-11 to 2015-16. 2. Since, the issues involved in all these appeals are similar, they were heard together and being adjudicated by a common order. 3. In ITA No. 1317/Del/2023, f....

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....ts and in law, in confirming the penalty and rejecting the contention of the assessee that on an addition made on the basis of estimation no penalty under section 271(1)(c) can be levied. 5. On the facts and circumstances of the case, the learned CIT (A) has erred both on facts and in law in confirming penalty levied by the AO despite the fact that the addition itself is not tenable in la....

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....he AO rejecting the contention of the assessee that penalty was levied without giving finding on merits of the case as concealment of income as well as furnishing of inaccurate particulars of income. 9. On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in levying penalty despite the fact that there is neither concealment of income nor furnis....

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....: CIT vs. Manjunatha Cotton and Ginning Factory: 359 ITR 565 held that notice under section 274 should specifically state the grounds mentioned in section 271(1)(c) of the Act, i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. Sending printed form where all the grounds mentioned in section 271 are mentioned would not satisfy requirement of law. ....