KEDAR ASSOCIATES ,PUNE vs. TDS WARD 2 , PUNE

In the result, appeal of the assessee in ITA No

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1530 To 1533/Pun/2024 िनधा"रण वष" / Assessment Years : 2013-14 & 2014-15 Kedar Associates, Vs. Ito, Tds Ward-2, Pune. 105A Narayan Peth Off Lakmi Road, Pune- 411030. Pan : Aabfk6598A Appellant Respondent Assessee By : Shri Sharad A. Vaze Revenue By Shri Ramnath P. Murkunde : Date Of Hearing : 13.11.2024 Date Of Pronouncement : 29.11.2024 आदेश / Order Per Vinay Bhamore, Jm: The Above Captioned Four Appeals Filed By The Assessee Are Directed Against The Separate Orders Of Ld. Cit(A)/Nfac Dated 13.04.2023 For The Assessment Years 2013-14 & 2014-15 Respectively. 2. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Four Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. At The Outset, We Find That There Is Delay Of 400 Days In Filing Of These Appeals. Ld. Ar Furnished An Affidavit Explaining The Reasons Of Delay In Filing Of These Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Which Is Duly Supported By An Affidavit. Ld. Dr Raised No Serious Objection Against The Delay Condonation Request Made By The Assessee. Accordingly, The Delay Of 400 Days In Filing Of These Appeals Is Condoned & The Appeals Are Admitted For Adjudication. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1530/Pun/2024 For A.Y. 2013-14 (Quarter 2) For Adjudication.

274 days accordingly CPC (TDS), Ghaziabad has levied fees u/s 234E at the rate of Rs.200 per day while processing the return electronically on 23.11.2013. This intimation u/s 200A of the IT Act dated 23.11.2013 issued by the CPC (TDS), Ghaziabad for the Q2 of financial year 2012-13 was claimed to be not received by the assessee

KEDAR ASSOCIATES,PUNE vs. TDS WARD 2 PUNE, PUNE

In the result, appeal of the assessee in ITA No

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1530 To 1533/Pun/2024 िनधा"रण वष" / Assessment Years : 2013-14 & 2014-15 Kedar Associates, Vs. Ito, Tds Ward-2, Pune. 105A Narayan Peth Off Lakmi Road, Pune- 411030. Pan : Aabfk6598A Appellant Respondent Assessee By : Shri Sharad A. Vaze Revenue By Shri Ramnath P. Murkunde : Date Of Hearing : 13.11.2024 Date Of Pronouncement : 29.11.2024 आदेश / Order Per Vinay Bhamore, Jm: The Above Captioned Four Appeals Filed By The Assessee Are Directed Against The Separate Orders Of Ld. Cit(A)/Nfac Dated 13.04.2023 For The Assessment Years 2013-14 & 2014-15 Respectively. 2. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Four Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. At The Outset, We Find That There Is Delay Of 400 Days In Filing Of These Appeals. Ld. Ar Furnished An Affidavit Explaining The Reasons Of Delay In Filing Of These Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Which Is Duly Supported By An Affidavit. Ld. Dr Raised No Serious Objection Against The Delay Condonation Request Made By The Assessee. Accordingly, The Delay Of 400 Days In Filing Of These Appeals Is Condoned & The Appeals Are Admitted For Adjudication. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1530/Pun/2024 For A.Y. 2013-14 (Quarter 2) For Adjudication.

274 days accordingly CPC (TDS), Ghaziabad has levied fees u/s 234E at the rate of Rs.200 per day while processing the return electronically on 23.11.2013. This intimation u/s 200A of the IT Act dated 23.11.2013 issued by the CPC (TDS), Ghaziabad for the Q2 of financial year 2012-13 was claimed to be not received by the assessee

KEDAR ASSOCIATES,PUNE vs. TDS WARD 2 , PUNE

In the result, appeal of the assessee in ITA No

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1530 To 1533/Pun/2024 िनधा"रण वष" / Assessment Years : 2013-14 & 2014-15 Kedar Associates, Vs. Ito, Tds Ward-2, Pune. 105A Narayan Peth Off Lakmi Road, Pune- 411030. Pan : Aabfk6598A Appellant Respondent Assessee By : Shri Sharad A. Vaze Revenue By Shri Ramnath P. Murkunde : Date Of Hearing : 13.11.2024 Date Of Pronouncement : 29.11.2024 आदेश / Order Per Vinay Bhamore, Jm: The Above Captioned Four Appeals Filed By The Assessee Are Directed Against The Separate Orders Of Ld. Cit(A)/Nfac Dated 13.04.2023 For The Assessment Years 2013-14 & 2014-15 Respectively. 2. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Four Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. At The Outset, We Find That There Is Delay Of 400 Days In Filing Of These Appeals. Ld. Ar Furnished An Affidavit Explaining The Reasons Of Delay In Filing Of These Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Which Is Duly Supported By An Affidavit. Ld. Dr Raised No Serious Objection Against The Delay Condonation Request Made By The Assessee. Accordingly, The Delay Of 400 Days In Filing Of These Appeals Is Condoned & The Appeals Are Admitted For Adjudication. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1530/Pun/2024 For A.Y. 2013-14 (Quarter 2) For Adjudication.

274 days accordingly CPC (TDS), Ghaziabad has levied fees u/s 234E at the rate of Rs.200 per day while processing the return electronically on 23.11.2013. This intimation u/s 200A of the IT Act dated 23.11.2013 issued by the CPC (TDS), Ghaziabad for the Q2 of financial year 2012-13 was claimed to be not received by the assessee

VTP FOODS,PUNE vs. ITO WARD 7 (3), PUNE

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

condonation of delay of 519 days in filing the appeal since there was reasonable cause on its part for not filing the appeal within the prescribed time limit. 2] The learned CIT(A) has erred in confirming the addition of Rs.50,99,000/- made u/s 69A r.w.s. 115BBE of the Act on account of cash deposit in the bank account

SACHIN BADRINARAYAN SOMANI,PUNE vs. ITO WARD , HINGOLI

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं./Ita No. 2112 & 2113/Pun/2025 धििेंारण वर्ा /Assessment Year: 2013-14 Sachin Badrinarayan Somani, Ito Ward, Hingoli Rathi Rathi & Co., 501-504, Akshay Landmarks, Oppo. Pu Vs. La Garden, Sinhagad Road, Pune-411030 Maharashtra Pan-Cncps2724N अपीलेंर्थी / Appellant प्रत्यर्थी / Respondent Assessee By: Shri Nemin Shah Department By: Shri Ganesh B. Budruk-Addl. Cit Date Of Hearing: 18-12-2025 Date Of Pronouncement: 23-12-2025 आदीश /Order

condoning the delay in filing of appeal as the delay was due to unforeseen circumstances beyond the control of the appellant. Ground 3: On the basis of facts and circumstances of the case and in law, the Lid. CIT(A) bas ermed in maintaining the penalty of Rs. 71,75,281 under section 271(1)(c) of the Act levied

SACHIN BADRINARAYAN SOMANI,PUNE vs. ITO WARD , HINGOLI

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं./Ita No. 2112 & 2113/Pun/2025 धििेंारण वर्ा /Assessment Year: 2013-14 Sachin Badrinarayan Somani, Ito Ward, Hingoli Rathi Rathi & Co., 501-504, Akshay Landmarks, Oppo. Pu Vs. La Garden, Sinhagad Road, Pune-411030 Maharashtra Pan-Cncps2724N अपीलेंर्थी / Appellant प्रत्यर्थी / Respondent Assessee By: Shri Nemin Shah Department By: Shri Ganesh B. Budruk-Addl. Cit Date Of Hearing: 18-12-2025 Date Of Pronouncement: 23-12-2025 आदीश /Order

condoning the delay in filing of appeal as the delay was due to unforeseen circumstances beyond the control of the appellant. Ground 3: On the basis of facts and circumstances of the case and in law, the Lid. CIT(A) bas ermed in maintaining the penalty of Rs. 71,75,281 under section 271(1)(c) of the Act levied

RUPESH MAHENDRA KANKARIYA,AHMEDNAGAR vs. ITO WARD 1, AHMEDNAHGAR, AHMEDNAGAR

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.465/Pun/2025 िनधा"रण वष" / Assessment Year : 2013-14 Rupesh Mahendra Kankariya, Vs. Ito, Ward-1, Ahmednagar. B Namrata Marbles, Tilak Road, Ahmednagar- 414001. Pan : Arspk8493L Appellant Respondent Assessee By : Miss Kimaya Kudva Revenue By Shri Milind Debaje : Date Of Hearing 22.04.2025 : Date Of Pronouncement : 29.05.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.08.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2013-14. 2. The Assessee Has Raised The Following Grounds Of Appeal :- “1. On The Facts & Circumstances Of The Case & In Law, The Cit(A) Erred In; I. Concluding That The Appellant'S Request For Condonation Of Delay In Filing The Appeal Was Without Any Reasonable Cause, Rejecting The Application & Dismissing The Appeal In Limine. Ii. Dismissing The Appeal Ex-Parte Without Adjudicating The Ground Challenging Levy Of Penalty Of Appeal On Merits.

condonation of delay in filing the appeal was without any reasonable cause, rejecting the application and dismissing the appeal in limine. ii. Dismissing the appeal ex-parte without adjudicating the ground challenging levy of penalty of appeal on merits. 2 2. The appellant pleads that the notices seeking information and fixing hearing were served via email through ITBA portal

SMT. TARADEVI RATANLAL BAFNA,JALGAON vs. THE OF ASSISTANT COMMISSIONER INCOME-TAX, CENTRAL CIRCLE-2, NASHIK

Bench: Hon’Ble Shri S.S. Godara & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 296/Pun/2020 ननधधारण वषा / Assessment Year : 2015-16 Smt Taradevi R Bafna 91, Subhash Chow, Jalgaon. Pan : Aadpb9424E . . . . . . . अपऩलधथी / Appellant बनधम / V/S. Asstt. Commissioner Of Income Tax, Central Circle, Nasik . . . . . . . प्रत्यथी / Respondent द्वारा / Appearances Assessee By : Shri Sunil Ganoo Revenue By : Shri M. G. Jasnani सपनवधई की तधरऩख / Date Of Conclusive Hearing : 06/10/2022 घोषणध की तधरऩख / Date Of Pronouncement : 01/12/2022 आदेश / Order Per G. D. Padmahshali, Am; The Present Appeal Is Challenged Against The First Appellate Order Of Commissioner Of Income Tax (Appeals-12), Pune [For Short “Cit(A)”] Dt. 30/07/2018 For Assessment Year [For Short “Ay”] 2015-16 Passed U/S 250 Of The Income-Tax Act,1961 [For Short “The Act”] Which Emanated Out Of Order Of Penalty [For Short “Po”] Dt. 28/06/2017 Passed By The Acit, Central Circle-1(3), Nasik [For Short “Ao”] U/S 271Aab Of The Act.

delay stands condoned in the larger interest of justice. 8. We shall now deal with ground number 1 and 2 first, which alleges the deficiency in the SCN dt 28/12/2016 issued u/s 274 r.w.s. 271 to the appellant pursuant to which the penalty u/s 271AAB of the Act is levied, it’s apt to quote the text of the such

SAMARTH NAGARI SHAKARI PATH SANSTHA MARYADIT,PARBHANI vs. INCOME TAX OFFICER, WARD ONE, JALNA

Appeal is allowed in above terms

Bench: Shri Satbeer Singh Godara

condoning the delay. 2. (a) Under the facts and circumstances of the case and in law, the Learned AO has erred in disallowing the deduction of Rs.33,23,274/- under section

DINESH RAMDAS KIRVE,SATARA vs. ITO, SATARA

In the result, appeal of the assessee is allowed for statistical purpose

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1648/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15 Dinesh Ramdas Kirve, V The Income Tax Officer, At Post Kudal Post-Kudal, S Ward-4, Satara. Tal-Jaoli, Dist-Satara. Maharashtra – 415514. Pan: Aawopk6845P Appellant/ Assessee Respondent / Revenue Assessee By Shri Tanzil Padvekar(Virtual) Revenue By Shri Sandeep P Sathe – Jcit Date Of Hearing 06/10/2025 Date Of Pronouncement 09/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax Appeal(Nfac) Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2014-15 Dated 19.05.2025 Emanating From The Penalty Order Under Section 271(1)(C)Of The Income Tax Act, 1961 Dated 13.01.2022. The Grounds Of Appeal Raised By The Assessee Are As Under :

section 271(1)(c)of the Income Tax Act, 1961 dated 13.01.2022. The Grounds of appeal raised by the Assessee are as under : ITA No.1648/PUN/2025[A] “1) In the facts and circumstances of the case and in Law the Ld CIT(A) has decided the 1st appeal forgoing the facts that the quantum appeal against the impugned assessment order under

MAHESH VISHWANATH BHOIR,PUNE vs. INCOME TAX OFFICER, PUNE

In the result, both the above captioned appeals of the assessee are allowed for statistical purposes

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1813 & 1814/Pun/2024 िनधा"रण वष" / Assessment Year : 2011-12 Mahesh Vishwanath Bhoir, Vs. Ito, Ward-9(1), Pune. 3Rd Floor, Bhoir Building, Keshav Nagar, Chinchwad, Pune- 410033. Pan : Aihpb9631K Appellant Respondent Assessee By : None Revenue By : Shri Ramnath P. Murkunde Date Of Hearing : 29.01.2025 Date Of Pronouncement : 10.02.2025 आदेश / Order Per Manish Borad, Am: These Appeals Filed At The Instance Of Assessee Are Directed Against The Separate Orders Of Ld. Cit(A)/Nfac Dated 10.07.2024 Which Are Arising Out Of The Assessment Order Framed On 29.01.2014 U/S 144 & Penalty Order Framed On 17.07.2024 U/S 271(1)(C) Of The Act For Assessment Year 2011-12 By The Ito, Ward-9(1), Pune Respectively.

274 r.w.s. 271(1)(c) on 29.01.2014 but again assessee failed to appear resulting into levy of penalty of Rs.13,80,200/-. 4. Against the additions made by Ld. Assessing Officer, assessee preferred appeal before Ld. CIT(A)/NFAC against the additions made by the Assessing Officer and also the levy of penalty

MAHESH VISHWANATH BHOIR,PUNE vs. INCOME TAX OFFICER, PUNE

In the result, both the above captioned appeals of the assessee are allowed for statistical purposes

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1813 & 1814/Pun/2024 िनधा"रण वष" / Assessment Year : 2011-12 Mahesh Vishwanath Bhoir, Vs. Ito, Ward-9(1), Pune. 3Rd Floor, Bhoir Building, Keshav Nagar, Chinchwad, Pune- 410033. Pan : Aihpb9631K Appellant Respondent Assessee By : None Revenue By : Shri Ramnath P. Murkunde Date Of Hearing : 29.01.2025 Date Of Pronouncement : 10.02.2025 आदेश / Order Per Manish Borad, Am: These Appeals Filed At The Instance Of Assessee Are Directed Against The Separate Orders Of Ld. Cit(A)/Nfac Dated 10.07.2024 Which Are Arising Out Of The Assessment Order Framed On 29.01.2014 U/S 144 & Penalty Order Framed On 17.07.2024 U/S 271(1)(C) Of The Act For Assessment Year 2011-12 By The Ito, Ward-9(1), Pune Respectively.

274 r.w.s. 271(1)(c) on 29.01.2014 but again assessee failed to appear resulting into levy of penalty of Rs.13,80,200/-. 4. Against the additions made by Ld. Assessing Officer, assessee preferred appeal before Ld. CIT(A)/NFAC against the additions made by the Assessing Officer and also the levy of penalty

TULSABAI VASANT DESHMUKH,PUNE vs. INCOME TAX OFFICER, WARD 6(2), PUNE

In the result, all the appeals (ITA Nos

Bench: Dr. Manish Borad & Shri Vinay Bhamore

condone the delay of 1918 days in filing of each of the instant appeals before this Tribunal and admit these appeals for adjudication. 3 ITA.Nos.1837-1839/PUN./2025 (Amol Vasant Deshmukh & Ors.) 3. From perusal of the grounds of appeal, we notice that common grievance of the assessees is against the levy of penalty u/s.271

AMOL VASANT DESHMUKH,PUNE vs. INCOME TAX OFFICER, WARD 6(2), PUNE

In the result, all the appeals (ITA Nos

Bench: Dr. Manish Borad & Shri Vinay Bhamore

condone the delay of 1918 days in filing of each of the instant appeals before this Tribunal and admit these appeals for adjudication. 3 ITA.Nos.1837-1839/PUN./2025 (Amol Vasant Deshmukh & Ors.) 3. From perusal of the grounds of appeal, we notice that common grievance of the assessees is against the levy of penalty u/s.271

ROHINI MARUTI DESHMUKH,PUNE vs. INCOME TAX OFFICER, WARD 6(2), PUNE

In the result, all the appeals (ITA Nos

Bench: Dr. Manish Borad & Shri Vinay Bhamore

condone the delay of 1918 days in filing of each of the instant appeals before this Tribunal and admit these appeals for adjudication. 3 ITA.Nos.1837-1839/PUN./2025 (Amol Vasant Deshmukh & Ors.) 3. From perusal of the grounds of appeal, we notice that common grievance of the assessees is against the levy of penalty u/s.271

M/S. VIJAY CONSTRUCTION,,NASHIK vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE -2,, NASHIK

In the result, appeal of the assessee is allowed for statistical purpose

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.791/Pun/2019 िनधा"रणवष" / Assessment Year : 2012-13 M/S.Vijay Construction, The Acit, Central Circle- Row House 1, Suyojit Garden, Vs 2, Nashik. Gangapur Road, Sahdev Nagar, Nashik – 422005. Pan: Aagfv 5234 M Appellant/ Assessee Respondent /Revenue Assessee By Shri Pramod Shingte – Ar Revenue By Shri M.G.Jasnani – Dr Date Of Hearing 18/07/2022 Date Of Pronouncement 19/07/2022 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)-12, Pune For The A.Y. 2012-13 Dated 18.06.2018, Emanating Out Of Order Under Section 271(1)(C) Of The Act, 1961. The Assessee Raised The Following Grounds Of Appeal: “1. On The Facts & In The Circumstances Of The Case & In Law Ld. Commissioner Of Income Tax(Appeals)-12, Pune Erred Inpassing An Ex-Party Order Without Appreciating The Fact That Due To Valid & Sufficient Reasons Your Appellant Could Not Attend The Hearing & Without Considering The Merit Of The Case, Your Appellant Prays For Set Aside The Matter To The Cit (Appeals) In The Interest Of Principal Of Natural Justice.Without Prejudice To The Above Grounds Of Appeal. 2. On The Facts & In The Circumstances Of The Case & In Law Ld.Assessing Officer Has Erred In Wrongly Imposing The Penalty Under Section 271(1)(C) Of The Income Tax Act, 1961

delay condoned. 3. Brief facts of the case are that the Assessing Officer levied penalty under section 271(1)(c) of the Act for the A.Y. 2012-13. The assessee filed appeal against the said penalty order before the ld.CIT(A). However, the ld.CIT(A) vide his order dated 18.06.2018 dismissed the appeal as the assessee failed to appear before

TEJAS SHIVAJI ADSUL,KOLHAPUR vs. INCOME TAX OFFICER WARD 1(1), KOLHAPUR, KOLHAPUR

In the result, appeal of the assessee is allowed

Bench: Shri R.K. Panda & Ms. Astha Chandra

condone the said delay and proceed to decide the appeal. 2 ITA No.59/PUN/2025, AY 2018-19 3. Briefly stated, the facts of the case are that the assessee is an individual and engaged in family business of agriculture. For A.Y. 2018- 19, the assessee did not file his return of income. The case of the assessee was reopened

MARATHI BANDHKAM VYA vs. AYIK ASSOCIATION,PUNEVS.ITO, EXEMPTION WARD-1(1),PUNE, PUNE

In the result, the appeal filed by the assessee is partly allowed

condone the delay and proceed to adjudicate the appeal. 3. The appellant has raised the following grounds of appeal :- “The following grounds are taken without prejudice to each other- On facts and in law, 1. The learned CIT(A) erred in confirming the action of the Assessing Officer in treating the interest income earned on Fixed Deposits kept with banks

MAJHAR ISMAIL HASHMI SAYAD,PARBHANI vs. INCOME TAX OFFICER & TPS , PARBHANI

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri G. D. Padmahshali & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.783/Pun/2024 िनधा"रण वष" / Assessment Year : 2011-12 Majhar Ismail Hashmi Vs. Ito & Tps, Parbhani. Sayad, Near Datta Mandir, Gangakhed, Dist. Parbhani- 431514. Pan : Bzhps1440M Appellant Respondent Assessee By : None Revenue By : Umashankar Prasad Date Of Hearing : 22.07.2024 Date Of Pronouncement : 29.07.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 11.12.2023 Passed By Ld Cit(A)/Nfac For The Assessment Year 2011-12. 2. The Appellant Raised The Following Grounds Of Appeal :- “1. On The Facts & The Circumstances Of The Case & In Law, Lower Authorities Erred In Passing Ex-Parte Order & Erred In Deciding The Issue Only On The Basis Of Material Available With Them, This Action Is Being Violative Of Principal Of Natural Justice. Your Appellant Prays For Granting Opportunity Of Hearing Before Lower Authorities. Without Prejudice To The Above Grounds Of Appeal, Following Grounds Are Also Taken On Merit:

section 139 of the IT Act for the year under consideration. Therefore, a notice u/s 148 of the IT Act was issued on 27.03.2018 requesting the assessee to file his return of income. Thereafter, notice u/s 142(1) was issued on 11.07.2018. Since the assessee failed to file his return of income, a show-cause notice u/s 274 r.w.s. 271F