In the result, both the appeals filed by the assessee are partly allowed for statistical purposes
Bench: Shri Manomohan Das & Shri Rakesh Mishra
271(1)(c) of the Act but the principle enunciated is equally applicable to section 271AAB of the Act as well as the nature of the default is not only similar but also more severe. Since penalty u/s 271AAB of the Act is not included in section 273B of the Act, once the facts are on record that the case