A2Z MAINTENANCE & ENGINEERING SERVICES LTD.,GURGAON vs. DCIT, CENTRAL CIRCLE-II, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

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