2022 (4) TMI 1675

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....oner : Sri. Annamalai. S., Advocate. For the Respondent : Sri. K.V. Aravind, Advocate. ORDER 1. The petitioner has impugned the penalty order dated 29.03.2022 under Section 270A of the Income Tax Act, 1961 [for short "I.T. Act"] and the notice of demand under Section 156 of the I.T. Act. The petitioner's grievance with the impugned order and the notice of demand is that these are notwiths....

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....ch appeal immediately because of the Covid-19 pandemic and certain technical reasons. However, the petitioner has filed the appeal on 03.09.2021. The petitioner has also filed an appeal against the Assessment Order for the Assessment Year 2018-19. 4. The petitioner's case is that for the reasons that the petitioner cannot explain, a common acknowledgement has been generated for the Assessment Y....

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....nsel for the respondent, submits that it would be difficult to believe that with the automation, there can be two acknowledgements for the two appeals against different Assessment Orders. However, the fact whether the petitioner has filed necessary appeal in time for the Assessment Year 2018-19 can be easily verified and there need not be any hyper-technical approach. 7. Therefore, the petition....