2022 (1) TMI 929

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..... HI] therefore, the penalty would not survive. - Appeal of the assessee is allowed.
Vijay Pal Rao, Member (J) And Anadee Nath Misshra, Member (A) For the Appellant : Rakesh Gupta and Somil Agarwal, Advs. For the Respondents : Sarita Kumari, CIT (DR) ORDER Per Vijay Pal Rao, JM This appeal filed by the assessee is directed against the order dated 29.12.2018 passed by the Ld. CIT(A)-3, Gurgao .....

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..... opportunity of being heard and by not observing the principles of natural justice. 4) That the appellant craves the leave to add, alter or amend the grounds of appeal at any stage and all the grounds are without prejudice to each other." 2. We have heard the Ld. AR as well as Ld. CIT-DR and considered the material on record. The AO has levied the penalty u/s. 271AAA vide order dated 22nd .....

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..... the additions made by the AO in the quantum appeal vide order dated 3rd July, 2019 in ITA No. 1056/Del/2017 as under:- "7. We have heard both the parties and perused all the relevant material available on record. From the perusal of the records it can be seen that the jewellery belongs to wife of the assessee and not belong to the assessee. Thus, the said jewellery cannot be added in the in .....

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