In the result, both the appeals of the assessee are\nallowed
271H(3) that too by\nexpressly put bar for penalty under Section 272A by\ninsertion of proviso to Section 272A(2), it can be said\nthat a particular set up for imposition and the\npayment of fee under Section 234E was provided\nbut, it did not provide for making of demand of such\nfee under Section 200A payable under Section