In the result, all the three appeals filed by the assessee are partly allowed for statistical purposes
Bench: Shri George Mathan & Shri Rakesh Mishra
III. ITA No. 218/PAT/2025: 1. For that the ld. CIT (A) NFAC has erred in affirming imposition of penalty u/s 271(1)(b) amounting to Rs. 10,000/-. 2. For that the Ld. CIT (A) NFAC has failed to appreciate that imposing penalty without proper service of notice and adequate opportunity and thus has violated the principles of equity