(1.) SINCE , the issue involved in both the appeals is similar, they are heard together and disposed of by this common judgment.
(2.) BY way of these appeals, the appellantassessee seeks to challenge the order of the ITAT, Ahmedabad 'B' Bench, Ahmedabad (for short, 'the Tribunal'), Dated : 22.02.2001, rendered in ITA No.1391/AHD/1995 and ITA No.1392/AHD/1995 for the A.Y. -1986 -87, whereby, the Tribunal partly allowed both the appeals filed by the appellantassessee, though, only for statistical purposes.
(3.) THE brief facts giving rise to the present appeals are that the appellant -assessee is engaged in the business of boring of tubewells for farmers. The appellant -assessee filed its return of income for the assessment year 1986 -87. Pursuant thereto, the case of the appellant -assessee was examined and the AO imposed penalty of Rs.1,51,800/ - under Section 271(1)(c) and Rs.12,566/ - under Section 273(2)(a) of the Act, on the ground that assessee had failed to disclose its income truly and correctly. Being aggrieved with the same, the appellant -assessee approached the CIT(A), which dismissed both the appeals filed by the appellant -assessee. Hence, the appellant -assessee approached the Tribunal, wherein, the Tribunal passed the impugned common order. Hence, the present appeals.