272A(1)(d) of the Act on the assessee. ITA No.95& 96/Agr/2023 2. Since, both the appeals relate to the same assessee, therefore, both the appeals were taken up together for hearing and are being disposed off by this common consolidated order. 3. We shall first deal with assessee’s appeal in ITA No.95/Agr/2023 pertaining to levy of penalty u/s.270A