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TMI Blog2019 (5) TMI 776X X X X Extracts X X X X X X X X Extracts X X X X ..... PC Limited [ 1996 (12) TMI 7 - SUPREME COURT] the additional grounds raised by the assessee are purely legal ground and did not require fresh facts which is to be investigated and goes to the root of the matter. In the interest of justice, we admit the aforesaid additional grounds. We find that since these additional ground were not raised before the Ld. CIT(A), hence, the same requires adjudicati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... se and in law, the Id. CIT ( A) erred in upholding the levy of penalty of 47,43,320/- u/s 271(l)(c) of the Income tax Act,1961 merely on the basis of presumptions and suspicions, ignoring the various judicial pronouncements and material on record. 2. On the facts and in the circumstances of the case and in law, the Id. CIT ( A) erred in upholding the levy of penalty of 47,43,320/- u/s 271(l)(c) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d, the assessee may be allowed to raise the following additional ground in the interest of natural justice:- "3. That on facts and circumstances of the case and in law, the impugned penalty of ₹ 47,43,320/- levied under section 271(1)© of the Act is without jurisdiction, illegal and bad in law. 3.1 That the AO erred on facts and in law in not specifying whether the penalty is levied ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ndia in the case of NTPC Limited 229 ITR 383 (Supra), the additional grounds raised by the assessee are purely legal ground and did not require fresh facts which is to be investigated and goes to the root of the matter. In the interest of justice, we admit the aforesaid additional grounds. We find that since these additional ground were not raised before the Ld. CIT(A), hence, the same requires ad ..... X X X X Extracts X X X X X X X X Extracts X X X X
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