161 results for “penalty u/s 271”+ Section 2(14)clear
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In the result, the appeal is partly allowed
Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra
14. Ground No. 2 is against the order of the Ld. CIT(A) for not considering the fact that in the original assessment order u/s 147, the Ld. AO had initiated the penalty alleging the assessee to have furnished inaccurate particulars of income whereas in the penalty order u/s 271(1)(c), the penalty was imposed alleging the assessee