(1.) BOTH appeals are filed by assessee and are directed against two separate orders of Commissioner (Appeals), dated 31 -1 -1995, for the assessment years 1987 -88 and 1988 -89.
(2.) GROUND of appeal for both appeals is identical and reads as under "On the facts and circumstances of the case, the Commissioner (Appeals) has erred in not deleting entirely the penalty levied under section 271(1) (c) of the Income Tax Act, 1961"
(3.) ORIGINAL assessments in respect, of both these years were completed under the provisions of section 143(1) on 24 -11 -1987, and 12 -11 -1990, for assessment years 1987 -88 and 1988 -89, respectively. As per the claim of assessee, the assessee had received following gifts during the years under consideration <FRM>JUDGEMENT_172_LAWS(BOM)1_2003.html</FRM>