306 results for “penalty u/s 271”+ Natural Justiceclear
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In the result, all the 12 appeals filed at the instance of
Bench: Shri Kul Bharat & Shri Manish Borad
natural justice is offended. On the basis of such proceedings, no penalty could be imposed to the assessee. (s) Taking up of penalty proceedings on one limb and finding the assessee guilty of another limb is bad in law. (t) The penalty proceedings are distinct from the assessment pro ceedings. The proceedings for imposition of penalty though emanate from proceedings