Tribunal Rules Each Non-Compliance Notice Under Sec 142(1) Needs Separate Penalty; Single Notice Invalidates Penalty.

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....The Income Tax Appellate Tribunal (ITAT) held that every non-compliance with a notice u/s 142(1) gives a separate cause of action for levying penalty u/s 271(1)(b). There must be a specific initiation and issuance of notice u/s 271(1)(b) for each non-compliance, and the assessee must be put on notice. Initiating penalty proceedings and levying penalty u/s 271(1)(b) for non-compliance with a notice u/s 142(1) is incorrect. The Assessing Officer (AO) issued only one notice u/s 271(1)(b), which the assessee claimed was never received, and the AO imposed an ex-parte penalty u/s 271(1)(b), breaching principles of natural justice. The Commissioner of Income Tax (Appeals) [CIT(A)] did not verify the assessee's contentions and explanations regardin.........