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TMI Blog2024 (3) TMI 1097X X X X Extracts X X X X X X X X Extracts X X X X ..... the AO s corresponding twin identical show cause notices that he had not specified the corresponding limb u/sec. 270A(8) read with sub-section(9) thereof as was held in various judicial pronouncements G.R. Infraprojects Ltd. [ 2024 (1) TMI 163 - RAJASTHAN HIGH COURT] , Schneider Electric South East Asia (HQ) PTE Ltd. [ 2022 (3) TMI 1295 - DELHI HIGH COURT] and Prem Brothers Infrastructure LLP vs. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2018- 2019, arise against the National Faceless Appeal Centre s [in short NFAC ] as many orders dated 05th April and 29th September, 2023, having Din Orders nos. ITBA/NFAC/S/250/2023-24/1051888360(1) and 1056661604(1) respectively; in proceedings u/sec. 270A of the Income Tax Act, 1961 (in short the Act ). Heard both the parties. Case files perused. 2. It emerges during the course of hearing that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he had duly initiated the impugned proceedings u/sec. 270A of the Act not only in both these assessments dated 10.03.2021 but also his sec. 270A penalty orders have duly pinpointed the corresponding limb in identical paragraphs 7.1 by invoking sec. 270A (9) (a) of the Act and, therefore, the assessee hardly stands to gain from the foregoing unintentional mistake in the show cause notices. Mr. Nay ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a (HQ) PTE Ltd. vs. ACIT [2022] 443 ITR 186 (Del.) (HC) and Prem Brothers Infrastructure LLP vs. NFAC [2022] 334 CTR 363 (Del.) (HC). We further wish to draw support from hon ble jurisdictional high court s decision in Mohd. Farhan A. Shaikh vs. DCIT [2021] 434 ITR 1 (Bom.)(HC) (FB) that such a failure on Assessing Officer s part in not specifying the relevant limb at the time of initiation of pen ..... X X X X Extracts X X X X X X X X Extracts X X X X
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