PADAM KUMAR JAIN,RANCHI vs. DCIT, CENTRAL CIRCLE-1, RANCHI

In the result, all the appeals filed by the assessee are allowed and copy of common order passed is to be placed on respective case files

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

3). Hence, the contention of the appellant that the penalty was levied on disallowance made u/s. 14/A and adhoc disallowance is factually incorrect. Under these circumstances the main issue is whether penalty u/s.271 (1)(c) is attracted in the case of the appellant or not. In order to appreciate the issue in proper perspective, the relevant provisions of section 271