ASHWANI KUMAR MISHRA,J. - (1.) The first appellate authority as well as the tribunal have concurrently held that the transaction has been duly accounted for and there was no intention to evade tax. With such finding, the order imposing penalty has been set aside.
(2.) Learned Standing Counsel although has advanced various submissions but the finding returned on factual aspect has not been shown to be perverse or erroneous.
(3.) Sri R.R. Agarwal, Senior Advocate, assisted by Sri Suyash Agarwal, learned counsel for the assessee submits that this Court is not required to reappraise the facts in the present revision.;