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2002 (1) TMI 247 - ITAT AHMEDABAD
Extract:
.......ction 275. However, if no such satisfaction was recorded by the Assessing Officer, then penalty imposed in this case will be bad in law in ab initio. If the satisfaction is found to have been recorded by the Assessing Officer, then the penalty sustained by the CIT(A) shall stand confirmed. 19. For statistical purposes, the appeal is partly allowed.