Appeal filing procedures state to attach grounds of appeal and statement of facts alongwith form 35. What if statement of facts is not attached and left to presentation during hearing ? Is this how it works practically, if yes then are there any benefits of the practical approach ?
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Appeal against penalty u/s 271(c)
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Statement of facts and GOA should be filed with form 35. I donot know any practical incetives one gets by presenting statement of facts in hearing. I am quite dumbstruck as to non receipt of defect in application from office of cit (a).
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