Penalty u/s 271(1)(c)

1.Penalty  of Rs.5,00,000 u/s 271(1)(c) was deleted by CIT appeal on the ground that penalty order passed by A.O. was passed after six months u/s 275(1)(a) . 2.The revenue is in appeal before ITAT on the ground that i) The penalty order was received late by CIT ii) The case is covered under exception to small tax effect circular of CBDT para 10(a) iii) Appeal admitted by the High court in quantum case is not relevant since withdrawal application has been filed by the assessee as per Vivad  se Vishwas scheme. 3. On behalf of the assessee it was submitted…

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