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In the result, the assessee’s cross objections for Assessment Years
Bench: Shri N. V. Vasudevanand Shri Jason P. Boaz
natural justice and cannot be sustained. Thus once the proceedings are initiated on one ground, the penalty should also be imposed on the same ground. Where the basis of the initiation of penalty proceedings is not ITA Nos.2854 to 2860/Bang/2018 C.O. Nos.136 to 142/Bang/2019 Page 12 of 14 identical with the ground on which the penalty was imposed, the imposition