Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Bleita Nos.51 & 52/Gty/2021 Assessment Year: 2012-13 & 2013-14 Jay Kishan Mandal Ito, Ward-1, Nagaon C/O. Rahul Raj Jain & Co., H. No. 15, 1St Floor, Bye Lane-2, Vs Shaktigarh Path, Bhangagarh, G.S. Road, Assam-781005. Pan: Ajupm 6794 L (Appellant) (Respondent) Present For: Appellant By : None Respondent By : Shri N.T. Sherpa, Jcit Date Of Hearing : 16.05.2023 Date Of Pronouncement : 25.05.2023 O R D E R Per Sonjoy Sarma, Jm: The Captioned Appeals Are Filed By The Assessee Against Two Separate Orders Of Ld. Cit(A), Nfac Both Dated 26.08.2021 In Respect Of Assessment Year 2012-13 & 2013-14 Respectively. The Assessee Has Raised Common Grounds Of Appeal For Each Of The Assessment Years Under Consideration: “I. That The Ld. Cit(Appeals) Was Not Justified While Confirming The Penalty Imposed U/S 271(1)(C) Of The Income Tax Act, 1961. Ii. That The Appellant Prays Leave To Add, Amend, Alter, Delete Or Forego Any Of The Grounds Either Before Or During The Course Of Hearing.”

u/s 271(1)(c) of the Act and imposed penalty of Rs. 40,346/- on the assessee vide penalty order dated 29.06.2017. Aggrieved by the penalty order, assessee had filed an appeal before the ld. CIT(A). However, the assessee could not succeed before the ld. CIT(A) and the ld. CIT(A) upheld the order passed