In the result, appeal filed by the Assessee is dismissed
Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)
delay of 40 days is condoned, and the appeal is admitted for adjudication on the merits. 3. In the present appeal Assessee has raised the following grounds: 2 1. That the Learned PCIT has erred in law and facts and circumstance of the case invoking section 263 by directing the AO to initiate penalty u/s 270A when no penalty