In the result, the appeal of the assesse is allowed for statistical
Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee
272A(1)(d) of the Act without granting reasonable opportunity of being hard to the appellant. He further contended that he has confirmed the penalty without appreciating the facts of the case and passed the order without application of mind thereof. It is argued by the council that the learned CIT appeal has adjudicated the issue of quantum appeal