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2007 (5) TMI 264 - AT - Income TaxExtract: .......lower authorities are vacated. Since the impugned penalty is not leviable for failure of the AO to record satisfaction for the initiation of the penalty proceedings under s. 271(1)(c) of the IT Act, as discussed above, we do not consider it necessary to go into other submissions of the assessee. 7. The appeal of the assessee is accordingly allowed.
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