In the result, the appeal of the assessee is allowed
Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)
80P. The AO initiated penalty proceedings. During penalty proceedings, in compliance to letter dated 19.02.2019 issued by the Assessing Officer, the assessee submitted reply dated 25.02.2019 which has been reproduced at page 1 & 2 of the penalty order, as under : “ this is in reference to notice no. DCIT/C-6/JPR/2018-19 dated 19.02.2019. “ 2. That in the computation of the aforesaid assessment year