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legality of notice issued u/s 274 r.w.s. 270A/271AAB for both the assessment years for the first time before the Tribunal ... order passed by the Assessing Officer, imposing penalty u/s 2701 / 271AAB of the Act. Since the Ld. CIT(A) has not discussed

legality of notice issued u/s 274 r.w.s. 270A/271AAB for both the assessment years for the first time before the Tribunal ... order passed by the Assessing Officer, imposing penalty u/s 2701 / 271AAB of the Act. Since the Ld. CIT(A) has not discussed

addition penalty proceedings under Section 274 read with Section 271AAB(1A) of the Act. Thus, the claim of the petitioner falls flat, and therefore