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TMI Blog2023 (7) TMI 509X X X X Extracts X X X X X X X X Extracts X X X X ..... Kunal Sharma, Sr Standing Counsel. RAJIV SHAKDHER, J. (ORAL): 1. Issue notice. 1.1 Mr Kunal Sharma, learned senior standing counsel, accepts notice on behalf of the respondents/revenue. 2. Given the direction that we propose to issue, Mr Sharma says, that counter-affidavit need not be filed, and that he will argue the matter based on the record presently available with the Court. 2.1 Theref ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , the Assessing Officer (AO) had levied, on the petitioner, penalty amounting to Rs. 27,34,356/-. 8. Notably, before the CIT(A), there was no representation, either on behalf of the petitioner/assessee or the respondents/revenue. 9. The petitioner avers, that the quantum levy imposed on the petitioner via assessment order dated 29.12.2011 was set aside by the Tribunal in the earlier round. 10. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... As would be evident, the CIT(A)'s order dated 29.12.2017, which was set aside by the Tribunal via impugned order dated 26.12.2022 arose out of the earlier penalty order dated 18.03.2014, which in turn was founded on the assessment order dated 29.12.2011. 13. It is the contention of Mr Dinesh Mohan Sinha, who appears on behalf of the petitioner, that the Tribunal should not have remanded the matt ..... X X X X Extracts X X X X X X X X Extracts X X X X
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