In the result, grounds of appeal raised by the assessee are allowed
Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay
Penalty proceedings under Section 271(1)(c) of the Act was also initiated in this case. 5. Subsequently, the ld. PCIT vide its order under Section 263 of the Act for the A.Y. 2012-13 dated 03/12/2020, set aside the assessment order dated 29/12/2017 passed under Section 153A/143(3) of the Act on the ground that the said assessment order