In the result, both the appeals filed by the assessee are partly allowed for statistical purposes
Bench: Shri Manomohan Das & Shri Rakesh Mishra
2) No penalty under the provisions of section 270A or clause (c) of sub-section (1) of section 271 shall be imposed upon the assessee in respect of the undisclosed income referred to in sub-section (1) or sub-section (1A). (3) The provisions of sections 274 and 275 shall, as far as may be, apply in relation