(1.) THE Revenue has preferred this appeal under s. 260A of the IT Act, 1961 (for short, "the Act") against the order of proposing to raise following substantial questions of law :
(2.) DURING the assessment, the AO made additions on account of disallowance and also levied penalty on that ground. The CIT(A) deleted the penalty holding that mere disallowance was not a ground for levying penalty in absence of any concealment or giving of inaccurate particulars. This view has been upheld by the Tribunal by observing as under :
(3.) WE have heard learned counsel for the appellant.