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TMI Blog2023 (9) TMI 889X X X X Extracts X X X X X X X X Extracts X X X X ..... s claimed by the assessee for want of evidences - HELD THAT:- AO has initiated the penalty proceedings for concealment of income and while levying the penalty the AO has levied it for furnishing the inaccurate particulars of income. This shows that the AO was not certain under which limb of section 271 (1)(c) the penalty was levied. Secondly if the AO was of the opinion that the assessee is en ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eals by the assessee preferred against the four separate orders of the CIT(A)-24, New Delhi dated 22.02.2023 pertaining to A.Y. 2013-14 to 2016-17. 2. The common grievance in all these appeals relates to the levy of penalty u/s. 271 (1)(c) of the Act though the quantum of penalty may differ in each year. 3. Since under lying facts are identical in all the appeals, therefore, they were heard ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nishing inaccurate particulars of income. 7. We have given a thoughtful consideration to the assessment order and also the order levying the penalty read with order of the first appellate authority to confirm the levy. 8. We are of the considered view that initially the AO has initiated the penalty proceedings for concealment of income and while levying the penalty the AO has levied it for f ..... X X X X Extracts X X X X X X X X Extracts X X X X
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