2024 (3) TMI 1097

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....T. ORDER PER SATBEER SINGH GODARA, J.M. : These assessee's twin appeals I.T.A. Nos. 708 & 1089/PUN./2023, for assessment years 2017-2018 & 2018- 2019, arise against the National Faceless Appeal Centre's [in short "NFAC"] as many orders dated 05th April and 29th September, 2023, having Din & Orders nos. ITBA/NFAC/S/250/2023-24/1051888360(1) and 1056661604(1) respectively; in proceedings u/sec.....

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....on the other hand has vehemently argued that the Assessing Officer's identical show cause notices hereinabove only suffer from an unintended omission as he had duly initiated the impugned proceedings u/sec. 270A of the Act not only in both these assessments dated 10.03.2021 but also his sec. 270A penalty orders have duly pinpointed the corresponding limb in identical paragraphs 7.1 by invoking sec....

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....ements G.R. Infraprojects Ltd. vs. ACIT [D.B. Civil Writ Petition no. 5594/2023 - Rajasthan High Court dated 02.01.2014]; Schneider Electric South East Asia (HQ) PTE Ltd. vs. ACIT [2022] 443 ITR 186 (Del.) (HC) and Prem Brothers Infrastructure LLP vs. NFAC [2022] 334 CTR 363 (Del.) (HC). We further wish to draw support from hon'ble jurisdictional high court's decision in Mohd. Farhan A. Shaikh vs.....