2. Since, the issues involved in all these appeals are identical, they were heard together and being adjudicated by a common order.
3. In ITA No. 5821/Del/2019, following grounds have been raised by the assessee:
"1. That on the facts and circumstances of the case, the penalty order passed by the AO is bad both in the eyes of law and on facts.
2. That the Ld. CIT(A) has grossly erred both in law and on facts in upholding levy of penalty of Rs. 2,07,200/- u/s. 271(1)(c) of the Act.
3. That on the facts and circumstances of the case, the Ld. CIT(A) has erred both on facts & in law in upholding the levy of penalty u/s. 271(1)(c) of the Act without appreciating the fact that there was no concealment or furnishing of inaccurate particulars of income by the appellant as contemplated u/s. 271(1)(c) of the Act.
4. That on the facts and circumstances of the case, the Ld. CIT(A) has erred both on facts & in law in upholding levy of penalty of Rs. 2,07,200/- u/s. 271(1)(c) of the Act on addition sustained on ad-hoc, estimated basis without bringing any material on record to prove that there was concealment or furnishing of inaccurate particulars of income on the part of appellant.
5. That on the facts and in the circumstances of the case, the Ld. CIT(A) has erred both on facts & in law in upholding levy of penalty of Rs. 2,07,200/- u/s. 271(1)(c) of the Act without considering the fact that explanation offered by the appellant was not acceptable to the Ld. AO would not itself amount to concealment or furnishing of inaccurate particulars of income by the appellant as contemplated u/s. 271(1)(c).
6. That on the facts and in the circumstances of the case, the Ld. CIT(A) has erred both on facts & in law in upholding levy of penalty of Rs. 2,07,200/- u/s. 271(1)(c) of the Act, without appreciating the fact that the Ld. AO has imposed penalty by charging the appellant as guilty of furnishing inaccurate particulars of income by mechanically invoking provision of Explanation 1 of Section 271(1)(c) of the Act while the same can be invoked for the charge of concealment of income.
7. That on the facts and in the circumstances of the case, the Ld. CIT(A) has erred both on facts & in law in upholding levy of penalty of Rs. 2,07,200/- u/s. 271(1)(c) of the Act, without appreciating the fact that AO explicitly fails to specify in the show cause notice issued u/s. 274 r.w.s. 271 of the Act that under which limb of section 271(1)(c), penalty proceedings has been initiated i.e. either for concealment of income or for furnishing of inaccurate particulars of income, which makes the penalty order passed without jurisdiction, which is bad in law and liable to be quashed.
8. That on the facts and in the circumstances of the case, the Ld. CIT(A) has erred on facts & in law in justifying levy of penalty by arbitrary and mechanically applying the provisions of Explanation 5A of Section 271(1)(c) without appreciating the fact that no addition was made on the basis of an........