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In the result, both the appeals filed by the assessee are partly allowed for statistical purposes
Bench: Shri Manomohan Das & Shri Rakesh Mishra
21 and 2021-22 dated 08.11.2024, which have been passed against the penalty orders u/s 271AAB of the Act, dated 20.09.2022, for both the years. Since the issues are common, both the appeals were heard together and are being decided vide this common order for the sake of convenience and brevity. I.T.A. Nos.: 256 & 257/GTY/2024 Assessment Years