CRYSTAL THERMOTECH PVT.LTD.,KOLKATA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, JAMSHEDPUR, JAMSHEDPUR
In the result, this appeal filed by the assessee is allowed
ITA 79/RAN/2022[2016-17]Status: DisposedITAT Ranchi10 Jun 2025AY 2016-17
Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay
Section 132(1)Section 132(4)Section 153ASection 271(1)(c)Section 274
42,971/- needs to be quashed.
2. That the very initiation of penalty is bad in law as the Ld. AO has failed to record a proper or transparent satisfaction in his notice while initiating proceedings under section 271(1)(c), thus rendering the entire penalty proceedings null and void.
3. That under the facts and circumstances, the initiation