(1.) HEARD Shri R.K. Upadhyay, learned counsel for the appellants and Shri P.K. Jain, learned counsel for the respondent.
(2.) THESE two appeals filed against the same judgement and order dated 3.11.2000 arising of penalty proceeding have been heard together and are being disposed of by this common judgement.
(3.) THE Income Tax Appeal No. 119 of 2001 has been filed against the same order of the Tribunal deleting the penalty under section 273 (2A) of the Act.