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In the result, the appeals of the assessee are allowed
Bench: Sh. C. M. Gargdr. B. R. R. Kumar
penalty levied under section 271(1)(b) of the Act on account of alleged non-compliance in proceedings under section 143(3) r.w.s. 153A I of the Act, is illegal and bad in law.” 5. Admission of the additional ground has been opposed in principle by the ld. DR. Keeping in view, the judgment of the Hon’ble Apex Court