Where penalty proceedings under section 271(1)(c) were initiated during pendency of assessee’s appeal against quantum assessment before the Tribunal and the Assessing Officer subsequently imposed a penalty of about Rs. 101 crores while such appeal was pending, under section 275 as it stood prior to 1-4-2025, a penalty order could not be passed during pendency of appeal against quantum assessment before ITAT; accordingly, ad-interim relief was granted restraining Revenue from taking any steps pursuant to the penalty order. Followed: R.B. Shreeram Durgaprasad v. CIT [2016] 237 Taxmann 189 (Bom)(HC)