KALIPADA SAHA,HOOHLY vs. ITO, WARD-24(3), HOOGHLY. , HOOGHLY
In the result, all the four appeals of the assessee are dismissed
ITA 1189/KOL/2023[2011-12]Status: DisposedITAT Kolkata12 Jun 2024AY 2011-12
Bench: Shri Rajpal Yadav & Shri Rakesh Mishra
For Appellant: N o n eFor Respondent: Shri B. K. Singh, Addl. CIT
Section 147Section 148Section 250Section 263Section 271(1)(c)
5. In the written submission filed, the assessee has raised two contentions as under:
(a)
Whether penalty u/s. 271(1)(c) of the Act is maintainable where the assessee voluntarily disclosed higher income in response to the notice u/s. 148 and paid tax thereupon and ;
(b)
That the Commissioner has no power to direct the AO to initiate penalty proceeding
