Dismissing the appeal of the revenue against single judge , division Bench  held that the assessees having been levied with penalty under S. 271D and 271E for contravention of S. 269SS will be entitled to have their applications processed for benefit of Direct Tax Dispute Resolution Scheme, 2016 as when a specified sum is so provided as penalty, such specified sum is minimum penalty payable and it does not mean that benefit of Scheme could only be claimed by those assessees who had been levied penalty under provisions of Act providing for minimum penalty and maximum penalty.