2020 (12) TMI 296

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..... e CIT(A) did not give sufficient opportunity of hearing to the assessee. CIT(A) was not right in dismissing the appeal of the assessee without giving proper opportunity of hearing. We are remanding back the entire issue to the file of the CIT(A) to be decided on merit. Needless to say, the assessee be given opportunity of hearing by following principles of natural justice. The appeal of the assess .....

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..... y manner, which is highly arbitrary, unjustified and against the principle of natural justice. 3. That, the CIT (A) has failed to appreciate, the provision of section 27IB are not applicable on the assessee appellant, because assessee has maintained proper books of account and accounts are also Audited by Chartered Accountant. 4. That, the CIT (A) has erred in not appreciating the facts .....

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..... income of ₹ 3,62,051 u/s 115JB. The Assessing Officer passed assessment order dated 16.12.2016 thereby assessing the income of the assessee at 14,41,64,257/-. Thereafter, the Assessing Officer passed the penalty order dated 12.05.2017 under Section 271B of the Income Tax Act, 1961. 4. Being aggrieved by the penalty order, the assessee filed appeal before the CIT(A). The CIT(A) dismissed t .....

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