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TMI Blog2024 (12) TMI 1168X X X X Extracts X X X X X X X X Extracts X X X X ..... nidas V.S., Sr. DR ORDER PER SUCHITRA KAMBLE, JUDICIAL MEMBER: This appeal is filed by the Assessee against order dated 26.06.2024 passed by the CIT(A), National Faceless Appeal Centre (NFAC), Delhi for the Assessment Year 2012-13. 2. The assessee has raised the following grounds of appeal :- "1. The learned CIT(A) has erred in law and facts in upholding penalty on the addition of Rs. 1,81,7 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... alance of Sundry Creditors amounting to Rs. 19,21,522/- and non-deduction of TDS under Section 40a(ia) of the Act amounting to Rs. 1,52,650/-. In respect of the said additions, the Assessing Officer initiated penal proceedings under Section 271(1)(c) of the Act. Notice under Section 274 read with Section 271(1)(c) of the Act was issued on 27.03.2015. The assessee has not filed any submissions befo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3.03.2020 and mentioned that the initiation of penalty proceedings for furnishing of inaccurate particulars and concealment of income for all the issues including that of addition of 20% of balance of Sundry Creditors, stock difference and non-deduction of TDS. But, in the notice, there was no mention regarding the particular limb of Section 271(1)(c) of the Act. The Ld. AR relied upon the decisio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tice under Section 274 read with Section 271(1)(c) of the Act dated 27.03,2015 has not expressed under which limb the penalty is initiated under Section 271(1)(c) of the Act. The decision of Hon'ble Apex Court in the case of Manjunatha Cotton & Ginning Factory (supra) is applicable in the present case. Besides this, the assessee has rightly submitted the closing stock details as well as the stock ..... X X X X Extracts X X X X X X X X Extracts X X X X
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