9911796707
TMI Blog2024 (1) TMI 597X X X X Extracts X X X X X X X X Extracts X X X X ..... ORDER PER SATBEER SINGH GODARA, J.M. : These twin assessees' as many appeals, for assessment year 2016-17, arise against the CIT(A)-3, Nagpur's separate orders in case No. CIT(A)-3/10063/2018-19 and No. CIT(A)-3/10068/2018-19, both dated 12.11.2020, involving proceedings u/s. 271AAB of the Income Tax Act, 1961 (in short "the Act"); respectively. Cases called twice. None appears at assessees' b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ay of 223 days in both these appeals in very terms. 3. We now advert to both these assessees' identical sole substantive grievance that the learned lower authorities have erred in law and on facts in levying the impugned sec.271AAB penalties of Rs. 2,05,000/- each i.e., @ 10% of the undisclosed income of Rs. 20,50,000/- in their cases, respectively. The department taken us to the CIT(A)'s det ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... validly issued. We find no merit in the assessees' stand once it has come on record that the impugned penalty has been levied @ 10% since falling in the first and foremost limb u/sec. 271AAB(1)(a)(i) to (iii) of the Act in the specified circumstances. Their identical contention therefore, that the Assessing Officer ought to have specified corresponding limb(s) to this effect fails to cut any ice ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
