In the result, the appeal filed by the assessee is allowed
Bench: Sri Pradip Kumar Choubey & Sri Rakesh Mishra
194 H of the Act. 18. In view of above, we set aside the order of the Id CIT(A) on this issue and direct the AO to delete the demand raised in respect of this issue under section 201(1) and 2O1(1A) of the Act in respect of all the three assessment years under consideration.” Emphasis Supplied