In the result, the quantum appeal of the assessee is allowed for\nstatistical purposes and the penalty appeals are allowed with the\nabove observation
271 AAC(i) & 270A of the Income-tax Act,\n1961 (the Act).\nITA No. 441/GTY/2025\n2.\nThe Id. Counsel for the assessee submitted that the assessment has\nbeen framed by the Id. AO u/s 144/ 144B of the Income-tax Act,\n1961 (the Act) vide order dated 23.12.2022, when the assessee\nfailed to make any compliance before