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In the result, the appeal filed by the assessee is allowed
Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)
3) r.w.s 153C of the Act on 07/05/2021 is rectified as under: “5.9 Therefore, the addition of Rs. 1,22,21,350/-(Rs.2,50,14,000- Rs. 1,06,92,650- Rs. 21,00,000) is being made under the head Profits and gains of business and profession. Penalty proceedings u/s 270A of Income Tax Act are hereby initiated