2023 (4) TMI 1469

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....see : Shri R.B Doshi, CA For the Revenue : Shri Piyush Tripathi, Sr. DR ORDER PER RAVISH SOOD, JM: The present miscellaneous application filed by the revenue arises from the order passed by the Tribunal in ITA No. 124/RPR/2015 for the A.Y. 2005-06 dated 13.08.2018. The revenue has filed the present miscellaneous application stating as under: "In this regard, it is stated that ....

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....s is apparent from the record." 2. On a perusal of the contents of the aforesaid miscellaneous application, we find that it is the claim of the revenue that the Tribunal while allowing the appeal of the assessee had failed to consider that the A.O had clearly stated in the body of the assessment order that the penalty proceedings u/s. 271(1)(c) were being initiated for "concealment of income" b....