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2005 (5) TMI 16 - DELHI HIGH COURT"(i) Whether Tribunal has erred in sustaining the penalty under section 271(1)(c) of the Act in the case of the appellant, for the assessment year 1992-93, inasmuch as the satisfaction of the Assessing Officer as contemplated in section 271(1)(c) of the Act was not recorded in the present case?" - we would answer the question of law in the affirmative and in favour of the assessee holding that the impugned order dated October 20, 2003 in so far as it relates to initiation of penalty proceedings is liable to be set aside
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