2024 (11) TMI 893

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ndent : Shri Vivek Kumar Upadhyay, Sr. DR ORDER PER VIKAS AWASTHY, JM: This appeal by the assessee is directed against the order of Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (hereinafter referred to as 'the CIT(A)') dated 27.02.2024, for assessment year 2007-08. 2. Shri Anil Bhalla, appearing on behalf of the assessee submits that during the course of....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....that another penalty notice dated 07.06.2019 was served on the assessee, the same is at page 79 of the paper book. In the subsequent notice, there was no mention of any limb of section 271(1)(c) of the Act, for which penalty is being levied. Therefore, the second notice is also ambiguous and invalid. 3. Shri Vivek Kumar Upadhyay, representing the department vehemently defended the impugned order ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....We have examined the notice dated 31.12.2009 and notice dated 07.06.201., An examination of the first notice reveal that it is in a preprinted performa, wherein both limbs of section 271(1)(c) of the Act have been mentioned. The Assessing Officer has not struck off irrelevant clauses in the preprinted performa. The omnibus notice is vague. The subsequent notice dated 07.06.2019 is equally ambiguou....