In the result, appeal in ITA No
Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar U.S.
275(1)(a) of the Act have not been appreciated which state that where the appeal is pending before the Hon’ble ITAT, the penalty proceedings should not be disposed of till the time specified under the said Section. 3. That on the facts and circumstances of the case and in law, the Hon’ble CIT(A) has erred