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2013 (5) TMI 854 - ITAT DELHI
Extract:
....... (1) © of the Act. The initiation of penalty proceedings u/s 271 (1) (c) of the Act, is an independent proceedings, hence it does not need any interference at this stage as the same is premature. The ground is accordingly rejected. 12. Consequently, both the appeals are partly allowed. The order is pronounced in the open court on 31 May/ 2013.