ITAT Remands Penalty Appeal Under Section 271DA for Fresh Hearing with Fair Opportunity per Rule 46A

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....The ITAT set aside the CIT(A)'s order and remitted the appeal for fresh adjudication, noting the assessee's failure to adequately respond to penalty notices under section 271DA for violation of section 269ST, relating to receipt of cash exceeding Rs. 2,00,000. The Tribunal observed that the CIT(A) had not disposed of the appeal on merits and condoned the delay in filing the appeal due to the assessee's incarceration, which hindered timely response. The ITAT directed the CIT(A) to provide the assessee a fair opportunity to represent the case and allow the AO to be heard pursuant to rule 46A of the Income Tax Rules, 1962, before passing a reasoned order in accordance with law. The matter is thus remanded to ensure adherence to principles of natural justice and proper consideration of the facts and submissions.....