he assessee has made out a prima facie case in favour of the assessee proving that the outcome of the appeal before Tribunal will directly impact the proceedings which are hurriedly being finalized by the authorities below, which may entail huge liability by way of penalty on the assessee. In our opinion, so long as the appeal is pending before the Tribunal, the Revenue authorities should be restrained from passing any order imposing penalty on the assessee under ss. 271C and 206AA of the Act however the proceedings may continue. While deciding so, we are supported by the decisions of the jurisdictional High Court in the cases of CIT vs. Wander (P) Ltd. (supra) and Asstt. CIT vs. GE India Technology (P) Ltd. (supra). We, therefore, respectfully following the decision of the Hon’ble Gujarat High Court, direct the Addl. CIT(TDS)/Revenue authorities not to pass orders imposing penalty for a period of six months from the date of this order or disposal of appeal by the Tribunal, whichever is earlier, however, the proceedings may be continued during this period. 7.The stay applications are disposed of as directed hereinabove and Revenue authorities directed not to pass orders imposing penalty under ss. 271C and 206AA for a period of six months from the date of this order or disposal of appeal whichever is earlier.