In the result, all the captioned seven appeal are allowed for statistical purposes
Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member
u/s 147. 7. Penalties Imposed Without Just Cause: Penalty proceedings initiated under Sections 271(1)(b), 271(1)(c), and 271F are unjustified, as the failure to file the return was due to operational shutdown and not due to any intention to evade tax. Moreover, taxes had already been paid in excess. 8. Procedural Lapses in Appeal Proceedings: The Learned