9911796707
TMI Blog2024 (8) TMI 163X X X X Extracts X X X X X X X X Extracts X X X X ..... s provided to Indian companies, AO made addition - AO also observed that as the assessee has under reported its income which is in consequence of misreporting thereof - HELD THAT:- We find substance in this argument as assessment order and penalty order are both silent on these submissions and, at the same time, make specific mention that no submissions were made. AR has also argued on the fact th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g notice of the explanation submitted along with subsequent developments of rectification of Form 26AS, we are inclined to allow the grounds. - Shri G.S. Pannu, Hon ble Vice President And Shri Anubhav Sharma, Judicial Member For the Assessee : Ms Soumya Singh, Advocate For the Revenue : Shri Vizay B. Vasanta, CIT-DR ORDER PER ANUBHAV SHARMA, JM: This appeal arises out of the penalty order dated ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... m 26AS and considering the same to be fees for technical services provided to Indian companies, made addition and also in the assessment order dated 22.11.2021 observed that as the assessee has under reported its income which is in consequence of misreporting thereof, it is a fit case for initiating penalty proceedings u/s 270A of the Act. Accordingly, show-cause notice was issued on 12.05.2022 an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... this argument as assessment order and penalty order are both silent on these submissions and, at the same time, make specific mention that no submissions were made. The ld. AR has also argued on the fact that the penalty notice is not a valid notice as there is no specific allegation of the fact of which misrepresentation was made or the fact which was suppressed for the purpose of specific limb ..... X X X X Extracts X X X X X X X X Extracts X X X X
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