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2007 (9) TMI 250 - HC - Income TaxPenalty was set aside by the Tribunal on the ground that the AO had not recorded any satisfaction in the assessment order that there was either concealment or inaccurate particulars furnished by the Assessee – no satisfaction of the Assessing Officer that penalty proceedings are required to be initiated against the Assessee is discernible - requirement of Section 271(1)(c) as explained by this Court in Ram Commercial Enterprises Ltd. not satisfied – penalty was rightly set aside by ITAT
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