2025 (3) TMI 2091

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....JCIT-DR ORDER PER: NARINDER KUMAR, JUDICIAL MEMBER. The assessee is in appeal by challenging order dated 5-11-2024 passed by the ld.CIT(A), NFAC, Delhi, relating to the assessment year 2012-13. 2. Vide impugned order, the ld. CIT(A) partly allowed the appeal of the assessee. 3. The assessee was before the ld. CIT(A), feeling aggrieved by the order of dated 27-01-2022 passed by the A....

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....ee is that while issuing above said notice u/s 274 r.w.s. 271(1)(c) of the Act, the AO was not sure if it was a case of concealment of particulars of income or that of furnishing of inaccurate particulars of income, and as such, impugned order having been passed without application of mind, deserves to be set aside, but, the ld. CIT(A) partly allowed the appeal thereby reducing the penalty to Rs. ....

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....ify the exact ground of violation. Rather, AO called for its explanation on the dual ground of factum of concealment of particulars of income or furnishing of inaccurate particulars of income. This goes to show that the AO was not sure as to what was the actual ground of violation by the assessee. Section 271(1)(c) has two limbs. Principles of natural justice require that the assessee should be....