2023 (12) TMI 1508

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....R For the Revenue : Sh. Rajesh Kumar, Sr. DR ORDER PER M. BALAGANESH AM, This appeal of the Assessee arises out of the order of the Learned Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi, [hereinafter referred to as 'Ld. CIT(A)'] in Appeal No. NFAC/2011-12/10060363 against the order passed by JCIT, Range-75, New Delhi (hereinafter referred to as the ....

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....p of nearly 8 years, the ld. AO directly levies penalty u/s 272A(2)(c) of the Act for belated filing of TDS returns by the assessee. At the outset, this penalty proceeding has been initiated without there being any order passed u/s 201(1) / 201(1A) of the Act framed on the assessee. Moreover, on perusal of the penalty order, we find that the ld. AO had not even mentioned what is the default commit....