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2018 (9) TMI 1093 - ITAT DELHIPenalty u/s 271(l)(c) - non recording of mandatory “satisfaction” as per law - Held that:- The original assessment order passed u/s 143(3)/147 has been partially confirmed by the CIT(A) and addition of ₹ 20,40,399/- was deleted. Thus, the penalty for original assessment order does not sustain in toto but partially. Therefore, it will be appropriate to remand back this issue to the file of the Assessing Officer as there is no order giving effect to the CIT(A)’s order. The matter is remanded back to the file of the Assessing Officer. Needless to say, the assessee be given opportunity of hearing by following principles of natural justice - Appeal of the assessee is partly allowed for statistical purpose.
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