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Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta
section 44AB of the Act, 1961. However, since we have remanded the quantum appeal back to the files of the ld. first appellate authority for adjudication on merits of the case, we also deem it fit and proper to remand this penalty appeal u/s 271B back to the ld. first appellate authority to decide the matter in tandem with