In the result, both the revenue appeals are allowed for statistical purposes
Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh
271(B) of the Act. It appears that the reasons for the delay shown before learned CIT(A) were that the said penalty order remained with the staff of the appellant assessee. It is only when appellant’s counsel, on going through the e-proceedings’ tab, became aware about the impugned penalty order. The limitation period for filing first appeal