2024 (1) TMI 310

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....a Somani, A.R. For the Revenue : Shri P.P. Barman, Addl. CIT ORDER PER SHRI RAJESH KUMAR, ACCOUNTANT MEMBER:- The assessee is in appeal before the Tribunal against the order of ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 07.03.2023, which is arising out of the order under section 271(1)(c) of the Income Tax Act, 1961 for A.Y. 2012-13 fr....

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....emption under section 11 of the Act on the ground of violation of provisions of sections 13(1)(c) and 13(1)(d) read with section 11(5) of the Income Tax Act, 1961. The ld. Assessing Officer initiated the penalty proceeding for furnishing inaccurate particulars of income and finally imposed penalty of Rs. 1,80,940/- being 100% of the tax sought to be evaded vide order dated 02.02.2022 passed under ....

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....lty, a copy of which filed at page no. 16 of the paper book, reveal that one of the limbs of penalty was not marked meaning thereby that the penalty notice has been issued in a standard format without application of mind in a mechanical manner. Ld. Counsel for the assessee submitted that the penalty order passed on the basis of such mechanical/standard notice, which deprives the assessee from resp....