High Court Invalidates Section 270A Penalty Order Due to Department's Failure to Consider Pending Appeal Status.

HC set aside penalty order u/s 270A and notice of demand u/s 156 due to procedural oversight. Department acknowledged they weren't informed about pending appeal proceedings where notice was issued after delay condonation. Matter remitted to National Assessment Unit, NFAC for fresh consideration. Court determined penalty proceedings should have considered existing appeal status before proceeding. Case highlights importance of disclosing concurrent proceedings and proper procedural sequence in tax penalty matters, particularly when appellate authority has already taken cognizance of the main appeal. .....

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