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2007 (1) TMI 282 - ITAT DELHI
Extract:
....... therefore, wrong in holding, in paragraph 7.9 of his order, that the Assessing Officer had recorded the requisite satisfaction in the assessment order. 10. For the aforesaid reasons, we agree with the ultimate conclusion of the CIT (Appeals) that the penalty was not justified. We confirm his decision and dismiss the appeal filed by the department.