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TMI Blog2018 (11) TMI 1605X X X X Extracts X X X X X X X X Extracts X X X X ..... eal has been preferred by the Assessee/Appellant, on feeling aggrieved against the order dated 23.05.2017 impugned herein, passed by the Ld. CIT(A)-Amritsar, u/s 250(6) of the I.T. Act, 1961 (hereinafter called as 'the Act'), whereby the penalty was partly sustained and directed to be restricted on the amount of addition of Rs. 5,21,323/-. 2. At the outset, the Ld. Counsel of the assessee submitt ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in his bank account maintained in IDBI Bank, Amritsar. The CIT(A) on appeal against the assessment order, vide order dated 29.03.2014 allowed the relief of Rs. 13,84,841/- out of total addition of Rs. 23,18,500/- and confirmed the balance addition of Rs. 933,659/-. Against the confirmation of addition of Rs. 933,659/-, the assessee and against the part deletion of addition Rs. 13,84,841/- the depa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er and satisfaction must be there either directly or indirectly and while levying the penalty , the A.O. must be sure under which limb, he is levying the penalty and it is trite that penalty cannot be levied for twin charges until and unless the satisfaction recorded under both the limbs separately and followed with correct notice u/s 274 of the Act, specifying exact limbs, because the penalty for ..... X X X X Extracts X X X X X X X X Extracts X X X X
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