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2017 (12) TMI 1282 - AT - Income TaxPenalty u/s 271(1)(c) - non recording of satisfaction by AO - Held that:- Recording of the satisfaction in the assessment order about the initiation of penalty is must. In absence of proper satisfaction about the initiation of penalty order the penalty is liable to be deleted. Thus, the submissions of the ld. AR for the assessee are convincible that the penalty was levied by assessing officer without proper satisfaction. In our view the ratio of decision in Reliance Petroproducts Ltd (2010 (3) TMI 80 - SUPREME COURT ) is directly applicable on the facts of the present case. Thus, the ld AR of assessee is succeeded in convincing us on his first two preposition that neither the AO recorded his satisfaction about initiating and in imposing the penalty on particular limb of section 271(1)(c) and there was difference of opinion on the disallowance of expenditure. Hence, the grounds of appeal raised by the assessee are allowed
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