In the result, the appeal is partly allowed
Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayआयकरअपीलसं./Ita No. 527/Asr/2024 िनधा"रणवष" / Assessment Year : 2020-21
270A of the Income Tax Act, 1961 has been wrongly initiated. 11.1 That the Assessee craves leave to add or amend the grounds of appeal before the appeal is finally heard or disposed of. 4. During the proceedings before us, the ld. Counsel for the Assessee has filed a detailed written submissions which is being considered and decided as under