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2021 (8) TMI 1285 - SC ORDERPenalty u/s 271(1)(c) - no proper recording of satisfaction - as per HC there is no record of satisfaction by the AO that there was any concealment of income or that any inaccurate particulars were furnished by the assessee. This being a sine qua non for initiation of penalty proceedings, in the absence of such petition, the two authorities have quite correctly ordered the dropping of penalty proceedings against the petitioner - HELD THAT:- We are not inclined to interfere with the impugned order. The special leave petition is, accordingly, dismissed.
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