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In the result, both the appeals of the revenue are allowed for statistical purposes
Bench: Shri R.K. Panda & Shri V.P. Rao
penalty order u/s. 271(1)(c) of the Act respectively for the assessment year 2012-13. 2. In the quantum appeal, the assessee raised following grounds : “1. On facts and circumstances of the case and in law, the Ld. CIT(A) erred in condoning the delay of more than 2 years merely on ground that the erstwhile directors