A2Z MAINTENANCE & ENGINEERING SERVICES LTD.,GURGAON vs. DCIT, CENTRAL CIRCLE-II, FARIDABAD
In the result, the appeal of the assessee is allowed
ITA 2631/DEL/2018[2008-09]Status: DisposedITAT Delhi28 Mar 2023AY 2008-09
Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma
For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274
u/s 274
r.w.s. 271(1)(c) is being issued separately”. Manifest as it is, the AO has most casually initiated the penalty proceedings without choosing to specify any limb. Clearly, the act of the AO is vitiated by the non application of mind about the nature of default and, in consequence, vitiates the ‘satisfaction’
contemplated under section 271
