In the result, both the appeals are allowed for statistical purposes
Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh
penalty order passed u/s. 271(1)(c) of the Act is consequential to the assessment order, both these appeals are being disposed of by the consolidated order for the sake of convenience and brevity. The facts of ITA No. 260/Agr/2025 only are being narrated as under : 3. At the very outset, it is noted that both these appeals were filed