JUDGMENT

Rajiv Shakdher, J. (Oral) - This appeal concerns Assessment Year (AY) 2013-14.

2. Via the instant appeal, the appellant/revenue seeks to assail the order dated 26.05.2023 passed by the Income Tax Appellate Tribunal [in short, "Tribunal"].

3. In the instant appeal, the Tribunal was called upon to adjudicate the legal tenability of two separate orders dated 30.09.2019 passed by the Commissioner of Income Tax (Appeals) [in short, "CIT(A)"] whereby he had deleted the penalty amounting to Rs.1,97,31,721/- and Rs.4,95,98,366/- levied under Section 271(1)(c) of the Income Tax Act, 1961 [in short, "Act"] concerning AY 2013-14 and AY 2014-15, respectively.

4. It is not in dispute that CIT(A) deleted the penalty imposed by the AO, in view of the quantum appeal preferred before this Court, concerning AYs 2013-14, 2014-15 and 2015-16.

5. The Tribunal while disposing of the appeal against the aforementioned order of the CIT(A) has made the following observations:

"8. We have heard the Ld. Representative of the parties and perused the material on records. We have also considered the decision of the Hon'ble Delhi High Court in Liquid Investment and Trading Co. (supra) and decision of Indore Be