In the result, both the appeals filed by the assessee are partly allowed for statistical purposes
Bench: Shri Manomohan Das & Shri Rakesh Mishra
u/s 271AAB amounting to Rs. 51,00,000/- levied by the AO is hereby confirmed. Ground No. 1 is dismissed accordingly.” 9. In the grounds of appeal, the assessee has stated that the penalty is not leviable in as much as it is not the ‘specified previous year’. In this context it is relevant to refer to the definition