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TMI Blog2022 (6) TMI 397X X X X Extracts X X X X X X X X Extracts X X X X ..... hanical manner and in standard format without mentioning one of the two limbs on which the penalty was proposed to be levied. In other words, the notice mentioned both the limbs i.e. considering of record as well as furnishing of income inaccurate manner which is not permissible under the Act. In view of these facts we do not find any infirmity in the order of Ld. CIT(A). Non-mentioning of relevan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ma Joshi, FCA For the Respondent : Shri Biswanath Das, Addl. CIT ORDER PER SHRI RAJESH KUMAR, AM: This is an appeal preferred by the revenue against the order of the Commissioner of Income Tax(Appeals)-3, Kolkata [hereinafter referred to as CIT(A) ] dated 12.06.2020 for the assessment year 2010-11. 2. The only issue raised by the revenue is against the order of Ld. CIT(A) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the memorandum of appeal is 21.01.2016 and hence discrepancy has crept in. We are therefore proceedings to hear the appeal on merit as the issue raised in the revenue s appeal is covered in favour of the assessee in two decision of Hon ble Jurisdictional High Courts namely CIT vs. SSA s Emerald Meadows in ITA No. 380 of 2015 order dated 23.11.2015 and in the case of CIT vs. Manjunatha Cotton and G ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as discussed in the appellate order. 5. After hearing the rival parties and perusing the material on record, we find that the notice u/s 274 read with Section 271(1)(c ) dated 13.08.2015 has been issued in a mechanical manner and in standard format without mentioning one of the two limbs on which the penalty was proposed to be levied. In other words, the notice mentioned both the limbs i.e. co ..... X X X X Extracts X X X X X X X X Extracts X X X X
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