(1.) THE present appeal was admitted on the following substantial question of law :
(2.) HOWEVER , since the assessee had concealed the income, the penalty proceedings under s. 271(1)(c) of the Act were initiated and after affording due opportunity the penalty was imposed.
(3.) THE assessee further assailed the same by way of an appeal (ITA No. 301/Chd/1992) before the Income -tax Appellate Tribunal, Chandigarh Bench (SMC) (hereinafter referred to as 'the Tribunal'). The said appeal was allowed in terms of