In the result, both the grounds of appeal raised by assessee are dismissed
Bench: Shri Pawan Singh & Dr. Arjun Lal Saini
4. On appeal before the ld. CIT(A) in quantum assessment, the appeal was dismissed. After dismissal of appeal, the assessee was given show cause notice under section 274 read with section 271(1)(c). The Assessing Officer recorded that despite service of show cause notice, the assessee has not availed opportunity to file its explanation. The Assessing Officer, therefore