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2006 (6) TMI 109 - HC - Income TaxWhether satisfaction of the officer initiating the proceedings u/s 271 can be said to have been recorded even in cases where satisfaction is not recorded in specific terms but is otherwise discernible from the order passed by the authority - Keeping in view the decision of HC in Ram Commercial Enterprises Ltd.’s case where it was held that it no satisfaction is recorded, penalty proceedings can’t initiated, we are of the view that question should be decided by Full Bench
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