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TMI Blog2019 (2) TMI 1326X X X X Extracts X X X X X X X X Extracts X X X X ..... 2015 filed by the assessee is directed against the order dated 18.02.2014 of the CIT(A)-XVII, New Delhi relating to A. Y. 2008-09. ITA No.3883/Del/2015 filed by the assessee is directed against the order dated 28.02.2018 of the CIT(A)-XVI, New Delhi relating to A. Y. 2008-09. For the sake of convenience these appeals were heard together and are being disposed of by this common order. 2. The asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... under :- 2. That the Ld. ITO has erred in law as much as on the facts of the case in imposing the impugned penalty of Rs. 4,27,770/- u/s 271 (1) (c) of the IT Act for the alleged concealment of income by way of furnishing alleged inaccurate particulars of its income. He has failed to appreciate that from either of two, only one can be opted/ selected whether the appellant has concealed the incom ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the case and in the interest of justice I deem it proper to restore this matter back to the file of the CIT(A) with direction to adjudicate the same. Needless to say the Ld. CIT(A) shall grant due opportunity of being heard to the assessee and decide the issue as per fact and law. The ground raised by the assessee is allowed for statistical purpose. 7. In the result, the appeal of the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X
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