M/S. THE CENTRAL COOPERATIVE BANK LTD. ,BHILWARA vs. ACIT, CIRCLE, BHILWARA
In the result, the appeal filed by the assessee is allowed
ITA 93/JODH/2018[2014-15]Status: DisposedITAT Jodhpur11 Aug 2023AY 2014-15
Bench: Shri Pavan Kumar Gadale & Shri Dr. Dipak P. Ripotem/S.The Central Vs. The Acit, Circle Cooperative Bank Ltd., Bhilwara. Mahendra Gargieya & Rajasthan. Associates, Adv , No537-538,5Thfloor, Mahimatrinity, New Sanganer Road, Jaipur – 302019, Rajasthan. Pan/Gir No. : Aaaat8126B Appellant .. Respondent Assessee By : None Revenue By : Ms. Nidhi Nair, Jcit -Dr Date Of Hearing 10.08.2023 Date Of Pronouncement 11.08.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The Commissioner Of Income Tax (Appeals), Ajmer Passed U/S 271(1)(C) & 250 Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal: M/S. The Central Cooperative Bank Ltd.,Bhilwara. 1.The Impugned Penalty Order U/S 271(1)(C) Of The Act Dated 18.05.2017 Is Bad In Law & On Facts Of The Case, For Want Of Jurisdiction & Various Other Reasons & Hence The Same Kindly Be Quashed.
For Appellant: NoneFor Respondent: Ms. Nidhi Nair, JCIT -DR
Section 143(1)Section 143(2)Section 143(3)Section 271(1)(c)Section 274
3. That the show cause notice issued u/s 274 r/w
271(1)(c) of the Act, is quite vague and did not at all specify which limb of Section 271(1)(c) of the Act, the penalty proceedings had been initiated i.e., whether for concealment particulars of income or furnishing of inaccurate particulars of income. The impugned penalty based