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TMI Blog2023 (7) TMI 1313X X X X Extracts X X X X X X X X Extracts X X X X ..... not specify the appropriate limb under which the penalty is sought to be imposed as to whether the penalty was being imposed for concealment of income or for furnishing inaccurate particulars. As relying on MS. MINU BAKSHI [ 2022 (7) TMI 1307 - DELHI HIGH COURT] notice for imposition of penalty u/s 271(1) (c) of the Act, did not specify which limb of the said provision the penalty was sought ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... [[Application filed on behalf of the appellant/revenue seeking condonation of delay of 21 days in filing the appeal] CM APPL. 38412/2023 [Application filed on behalf of the appellant/revenue seeking condonation of delay of 60 days in re-filing the appeal] 1. These are applications seeking condonation of delay in filing and re-filing. 2. According to the appellant/revenue, there is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d 31.03.2017 passed under Section 271(1)(c), read with Section 274 of the Income Tax Act, 1961 [in short, the Act ] passed by the Deputy of Commissioner of Income Tax [in short, DCIT ]. 10. Both the Tribunal and the CIT(A) set aside the penalty order on the ground that the notice issued to the respondent/assessee with regard to imposition of penalty did not specify the appropriate limb under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... IT and Anr. v M/s SSA s Emerald Meadows, passed in ITA No. 380/2015, dated 23.11.2015. (ii) Commissioner of Income Tax v Manjunatha Cotton and Ginning Factory (2013) 359 ITR 565 (Kar.) (iii) PCIT vs M/s Sahara India Life Insurance Company Ltd., passed in ITA No.475/2019, dated 02.08.2019. 7.1. To be noted, the Special Leave Petition filed against the judgement in SSA s Emerald (m ..... X X X X Extracts X X X X X X X X Extracts X X X X
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