2024 (2) TMI 1039

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....ainst the order of the ld. CIT (Appeals)-30, New Delhi dated 18.01.2023 for the assessment year 2012-13 confirming the penalty under section 271(1)(c) of the Income-tax Act, 1961 (for short 'the Act') amounting to Rs.15,22,861/-. 2. At the outset, it is noted that there is a delay of 114 days in filing the appeal before the ITAT. For the reasonable cause for filing the delayed appeal, ld. Counsel....

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....ised various grounds, at the outset, ld. Counsel of the assessee contended that the notice issued under section 274 read with section 271(1)(c) of the Act is a defective one. The charge has not been specified in the notice, hence referring to various decisions including that of Hon'ble jurisdictional High Court in the case of PCIT vs. Sahara India Life Insurance Co. Ltd. 432 ITR 84 (Del.), ld. Cou....