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2004 (5) TMI 594 - AT - Income TaxExtract: .......l High Court and applying the same to the facts of the present case, we hold that the non-reaching of satisfaction as required by section 271(1)(c) is a jurisdictional defect and, therefore, the penalty proceedings are bad on that score also. 13. In the result, the order of the CIT(A) cancelling the penalty is confirmed and the appeal is dismissed.
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