In the result, ITA No. 65/Agra/2017 is allowed, whereas ITA
Bench: Shri A. D. Jain
3. The ld. Counsel for the assessee has contended that in the circumstances of the case and in law the CIT(A) erred in confirming the penalty of Rs.4,25,420/- under section 271C of the Act, not appreciating the fact that there was a reasonable cause which prevented the assessee to act like a man of average intelligence