Penalty Order not become Invalid for mere wrong quoting of section

During the assessment proceeding, the Assessing Officer observed that tax liability of Rs.1,09,71,691/- on the income declared in the return of income was shown payable under section 140A of the Act. In view of non-payment of admitted tax liability under section 140A(1) of the Act the Assessing Officer asked the assessee to furnish the evidence of tax paid as computed in the return of income and issued show cause that in absence of no such evidence as why the penalty might not be levied for non-payment of admitted tax. In the show cause notice, the Assessing Off

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