Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita Nos.31 & 52 To 60/Pan/2022 िनधा"रण वष" / Assessment Years : 2013-14 & 2014-15 Kwality Animal Feeds Pvt. Vs. Dcit, Tds, Ghaziabad. Ltd., Plot No.12, Kwality House, Jamboti Road, Machhe Industrial Area, Belgaum- 590014. Pan : Aabck0589J Appellant Respondent Assessee By : Shri Omkar Godbole Revenue By : Shri Ashwini D. Hosmani Date Of Hearing : 06.09.2023 Date Of Pronouncement : 07.09.2023 आदेश / Order Per Bench : These Are The Appeals Filed By Assessee Against The Separate Orders Of The National Faceless Appeal Centre, Delhi [‘Nfac’] Dated 08.04.2022 For The Assessment Years 2013-14 & 2014-15 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In All The Above Captioned Ten Appeals, We Proceed To Dispose Of The Same By This Common Order. 3. For The Sake Of Convenience & Clarity, The Facts Relevant To The Appeal In Ita No.31/Pan/2022 For The Assessment Year 2013-14 Are Stated Herein.

19. Hence, it can be said that, the mechanism provided for enforceability of Section 200(3) or 206C (3) for filing of the statement by making it penal under Section 272A (2) (k) is done away in view of the insertion of Section 271H providing for penal provision for such failure to submit return. When the Parliament has simultaneously brought