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2011 (6) TMI 201 - AT - Income TaxPenalty - In the letter dt. 25th March 2004, the CBDT has advised that penalties u/s. 271-D and 271-E for violation of the provisions of Section 269-SS and 269-T, respectively, should not be indiscriminately imposed - it remained the allegation of the appellant that recovery action was taken by the A.O by attaching bank account of the appellant u/s. 226(3) on 29.3.2010 on the basis of first appellate order passed on 3rd Februry 2010 and was served upon the assessee on 31st March 2010 - t is thus a fit case for invoking the provisions laid down u/s. Subsections 2(B) of Section 254 of the Act to impose cost on the Revenue to be paid to the appellant to compensate the harassment caused by the officers of the Revenue at fault to the appellant to some extent - Decided in the favour of the assessee
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