In the result the appeal of the revenue is dismissed being devoid of merits
Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Hybrid Hearing) I.T.A. Nos. 292 & 293/Asr/2024 Assessment Years: 2016-17 & 2017-18
Penalty proceedings u/s 271 (1)(c) of the Act for concealing particulars of income are simultaneously initiated.” 8. The matter was carried in appeal before the first appellate authority and the Ld. CIT (A), has considered all materials on record and has arrived at the conclusion that in absence of any material brought on record there is not even