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2004 (3) TMI 395 - AT - Income TaxExtract: .......r which relates to imposition of penalty. Penalty proceedings are quasi-criminal proceedings and are independent and different proceedings as compared with the assessment proceedings. In our view, the above direction of the CIT(A) is bad in law and hence not tenable. We accordingly quash this direction also. 9. In the result, the appeal is allowed.
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