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2003 (5) TMI 191 - AT - Income TaxExtract: .......alty proceedings have been initiated, it cannot be assumed that such satisfaction it was arrived at. 8.1 In view of the above decisions, I am of the firm opinion that the learned CIT(A) was not justified in confirming the penalty levied by the AO under s. 271(1)(c) of the Act. Accordingly, I cancel the same. 9. In the result, the appeal is allowed.
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