In the result, the appeal filed by the assessee is allowed for statistical purposes
Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra
u/s 144/147 and penalty order under section 271(1)(c) of the Act, dated 21.12.2017 and 30.05.2018, respectively. Since the issues in both the appeals are related to the same assessee, both the appeals were heard together and I.T.A. Nos.: 261 & 262/PAT/2025 Assessment Year: 2014-15 Anil Kumar. are being decided vide this common order for the sake of convenience