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TMI Blog2023 (9) TMI 477X X X X Extracts X X X X X X X X Extracts X X X X ..... ainst the order dated 12-05-2013 passed by the ld. CIT(A) for assessment year 2011-12. 2. The grounds of appeal are as under:- Sr. No. Grounds of Appeal Tax effect relating to each Ground of appeal (see note below) The order passed by Ld CIT(A) is against law, equity and natural justice. N.A. 2. The Ld. CIT(A) has erred in law and on facts in upholding the penalty levied U/S 27 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Berna Gamni Seva Sahakari Mandali Limited. Based on the information, the Assessing Officer issued show cause notice dated 13-05-2019 for levy of penalty u/s. 271D in contravention of section 296SS of the Act. The assessee filed reply dated 20-05-2019 thereby stating that acceptance of loan of Rs. 1,42,000/- from the society was through banking channel and not in cash. The assessee submitted the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o be allowed. 6. The ld. Departmental Representative relied upon the penalty order and the order of the ld. CIT(A) and further submitted that the certificate issued by the bank was not disputed but the adjustments were not matching or corelated and therefore the penalty was rightly imposed and confirmed by the ld. CIT(A) 7. Heard both the parties and perused the material available on record. It ..... X X X X Extracts X X X X X X X X Extracts X X X X
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