(1.) THIS order shall dispose of both these references.
(2.) THESE references under Section 256(1) of the Income-tax Act, 1961, are at the instance of the Revenue in respect of the same assessee for the assessment years 1969-70 and 1970-71, for answering the following questions of law, namely :
(3.) CONSEQUENTLY, these references are answered against the Revenue and in favour of the assessee by holding that the Tribunal was justified in cancelling the penalty for both these years for the reasons given by us,