In the result, this appeal filed by the assessee is allowed
Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay
section 275 since appeal filed for quantum was pending before Hon'ble ITAT for hearing. U. A.O. Imposed penalty without considering merits of the addition. 2. For that Ld. A.O. initiated penalty proceeding as per assessment order which states that - "that the penalty proceeding U/s 271 (1