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2015 (8) TMI 1263 - AT - Income TaxPenalty under section 271(1)(c) - natire of satisfaction - Held that:- The AO has to satisfy whether the penalty proceedings be initiated or not during the course of the assessment proceedings and the AO is not required to record his satisfaction in a particular manner or reduce it into writing The scope of Section 27l(l)(c) has also been elaborately discussed in Union of India vs. Dharmendra Textile Processors (2008 (9) TMI 52 - SUPREME COURT) and CIT vs. Atul Mohan Bindal (2009 (8) TMI 44 - SUPREME COURT). The principle laid down in our view, has been correctly followed by the Revenue and we find no illegality in the department initiating penalty proceedings in the instant case. - Decided against assessee
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