P.M. Parashar, J.M. - (1.) THE assessee has filed ITA No. 2707/All/1991 against the order of Commissioner (Appeals) dated 26 -11 -1991, for the assessment year 1989 -90.
(2.) THE department has filed ITA No. 281/All/1992 against the order of Commissioner (Appeals) dated 26 -11 -1991. The department has also filed ITA No. 915/All/1992 against the order of Commissioner (Appeals) passed under section 154 of the Income Tax Act, 1961, dated 17 -12 -1991, for the assessment year 1989 -90.
(3.) ALL the three appeals, which relate to the same assessee and in which some common issues are involved, are being decided by the common order. ITA No. 2707/All/1991 Through this appeal, the assessee has objected to the findings of the Commissioner (Appeals) sustaining penalty under section 271(1)(c) of the Income Tax Act, 1961, on the additions contained in ground No. 1, which is reproduced below : "1. That the learned Commissioner (Appeals) has erred in law and on facts in sustaining the penalty under section 271(1)(c) on the following additions/disallowances : JUDGEMENT_137_LAWS(ALL)1_20011.html;