The appeal of the assesse is allowed\nfor statistical purpose
penalty proceeding u/s 271(1)(b) of the\nIncome Tax Act is initiated separately\".\n2.4 That the assessee being aggrieved by the aforesaid\n\"impugned assessment order” prefers the first appeal u/s 246A\nof the Act before the Ld. CIT(A) who by the “impugned order\" has\ndismissed the 1st appeal of the assessee on the grounds and\nreasons stated