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2007 (6) TMI 231 - ITAT BOMBAY-G
Extract:
....... the absence of proper satisfaction of existence of any of the conditions which attract penalty. We, therefore, of the view that penalty in the instant case cannot be levied either for want of satisfaction or on account of Explanation 1 to section 271 (1)(c) of the Act. Hence we delete the same. 26. In the result, appeal of the assessee is allowed.