In the result, the appeal is allowed in the terms indicated above
Bench: Dr. Arjun Lalsaini. & Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 269/Rjt/2019 (Assessment Year: 2017-18) (Hybrid Hearing) Bharatbhushan Kishanlal Vs. The Income Tax Officer, Gupta, (International Taxation) Prop. Of Aqua Shipping, Suit - Gandhidham – 370210 100, Grain Merchant Association Bldg., 2Nd Floor, Plot No. 297, Wd – 12B, Gandhidham – 370001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afcpg3849N (अपीलाथ"/Assessee) (""यथ"/Respondent)
penalty proceedings u/s 271(1)(c) of the Act, mechanically. 8. The learned Commissioner of Income Tax (Appeals) erred on facts as well as in law in confirming the charging of interest u/s. 234A, 234B, and 234C of the Act, when addition itself not sustainable.” 3. Additional ground raised by the assessee, is as follows: "The Order passed u/s