SAGAR DUTTA Vs. CIT

JUDGEMENT

(1.) The Court--Both these two appeals were taken up together because the common questions of law have arisen in these two appeals.

(2.) The appellant, Amal Ganguly, was served with a notice to show cause why penalty under section 271B shall not be imposed upon him. To be precise the relevant portion of the show cause notice reads as follows:--

(3.) An identical notice was issued to the appellant, Sagar Dutta, which reads as follows:--