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Penalty u/s. 271(1)(c) - scope of Section 275(1A) - once substantial question of law against quantum additions are admitted by Hon’ble HC u/s 260A, the tribunal shall refrain from deciding even penalty on merits and the most appropriate course of action in such situations for tribunal shall be restore the matter back to the AO to adjudicate afresh levy of penalty u/s 271(1)(c) against assessee r.w.s. 274 & 275(1A) - remanded