In the result, all the captioned appeals of the assessee for A
Bench: Dr. Manish Borad, Am & Shri Sonjoy Sarma, Jm
ii. That the quantum appeal is admitted is admitted by the higher authority, it means that the issue is debatable and therefore, penalty u/s 271(1)(c) of the Act cannot be levied. iii. Ld. CIT (A) erred in enhancing the penalty without issuing show cause. 04. So far as in ITA Nos.54 & 55/PAT/2021 are concerned, the assessee has raised