2021 (3) TMI 1498

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....espondent : Shri Brajendra Kumar, DR ORDER PER MAHAVIR SINGH, VP : These appeals of assessee are arising out of the orders of the Commissioner of Income Tax (Appeals)]-17, Mumbai, [in short CIT(A)], in ITA Nos. 644/10140/17-18, CIT(A)-17/IT-641/10139/17-18, CIT(A)-17/IT-642/10089/17-18 CIT(A)-17/IT even date 28.02.2020. The assessments were framed by the Dy. Commissioner of Income Tax, Wa....

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....d physical appeal on 13.07.2020 with a covering letter enclosing that these appeals were filed through e-mail on 02.06.2020. Therefore, it was contended that first of all there is no delay in filing of appeal and secondly if there is a delay of 29 days i.e. also a technical delay. When these facts were confronted to the learned Sr. Departmental Representative, he fairly agreed that delay can be co....

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.... "1. The penalty proceedings is bad in law and on the facts of the case. The show cause notice is defective. 2. The Ld. CIT(A) has erred in law and on the facts of the case in confirming the action of Assessing Officer levying penalty of Rs.80,85,480/- under section 271(1)(c) of the Income Tax Act. The actin is unjustified and unwarranted. 3. You petitioner crave leave t....