Case Law Details
Case Name : Mr.Lakhamshi J. Gala Vs DCIT (ITAT Mumbai)
Related Assessment Year :
Courts :
All ITAT ITAT Mumbai
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Brief of the case: ITAT Mumbai held in J. Gala Vs DCIT that for levying the penalty u/s 271(1)(b) revenue has to give a reasonable opportunity of being heard to the assessee, without which penalty could not be levied. Further for giving reasonable opportunity of being heard, AO should give a separate notice to the assessee that failure to reply by the assessee penalty u/s 271(1)(b) would be levied.
Moreover initializing the penalty in the same order through which AO w
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In u/s 271(1)(b) there is any imprisonment