Penalty quashed as AO not specified under which limb he intended to impose Penalty

Babita Khurana Vs DCIT (ITAT Delhi) In so far as the factual aspect is concerned, there is no dispute that in response to notice issued u/s. 153A of the Act, the Assessee had filed revised returns of income declaring more income than what was declared in the original returns of income. It is further observed, in the course of assessment proceedings, the Assessing Officer made thorough verification of the returns of income and ultimately accepted the income declared by the Assessee. In other words in the assessment orders, the Assessing Officer has not made any variation to the income declared ...