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2001 (11) TMI 213 - AT - Income TaxExtract: ....... would satisfy the conditions under s. 275. However, if no such satisfaction was recorded by the AO, then penalty imposed in this case will be bad in law ab initio. If the satisfaction is found to have been recorded by the AO, then the penalty sustained by the CIT(A) shall stand confirmed. 14. For statistical purposes, the appeal is partly allowed.
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