Penalty u/s 158BFA(2) Not Automatic Without Appeal; Tribunal's Partial Addition Upheld Not Sufficient for Penalty.

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....Penalty u/s 158BFA(2) - merely because the part of the addition has been confirmed by the Tribunal and the assessee has not filed appeal before the Hon’ble High Court does not mean that the assessee is liable to penalty u/s 158 BFA(2). - AT....