TMI Blog2024 (11) TMI 1309X X X X Extracts X X X X X X X X Extracts X X X X ..... HELD THAT:- This being the clinching fact emerging from the case file, the hon ble jurisdictional high court in PCIT Ors. V. M/s Sahara India Life Insurance Co. Ltd. [ 2019 (8) TMI 409 - DELHI HIGH COURT] has already settled the issue in taxpayer s favour and against the department that such failure indeed vitiates the entire penalty proceedings. Accordingly, accept the assessee s sole substantive ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the learned Assessing Officer s penalty show cause notice dated 23.12.2016 that he had nowhere stated the specific limb as to whether it is an instance of concealment or that of furnishing of inaccurate particulars thereof. This being the clinching fact emerging from the case file, the hon ble jurisdictional high court in PCIT Ors. V. M/s Sahara India Life Insurance Co. Ltd. 2019(8) TMI 409 (Delh ..... X X X X Extracts X X X X X X X X Extracts X X X X
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