In the result, Ground Nos
Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal
244A the appellant wholly denied the payment of such liability in consequences of addition. ITA Nos.1594 to 1597/Ahd/2019 & 685/Ahd/2023 Jet Air Agencies Pvt. Ltd. vs. ACIT Asst.Years– 2010-11 to 2012-13 9. That the Commissioner of Income Tax (Appeal) erred on facts and in law in initiating issue of notice u/ 274 of the Act to initiate penalty proceeding