TMI Blog2009 (9) TMI 656X X X X Extracts X X X X X X X X Extracts X X X X ..... ndment - Penalty proceedings under section 271(1)(c) - held that whether satisfaction existed and was not recorded during assessment was not a matter of form but of substance and the absence of satisfaction could not be inferred from the omission to use particular words in the order of assessment. The same could be inferred from overall findings in the order of the assessment. appeal is allowed an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ance Bill, 2008, cannot be said to be erroneous and the amended provisions of section 271(1B) are not applicable in the cases decided prior to the insertion of this amendment ? (ii) Whether the hon'ble Income-tax Appellate Tribunal was correct in law in ignoring the ratio of the judgment of the jurisdictional Pun-jab and Haryana High Court in the case of M/s. Nakodar Co-op. Sugar Mills Ltd., I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . In Pearey Lal and Sons (EP) Ltd. [2009] 308 ITR 438 (P H), the earlier observations in Munish Iron Store [2003] 263 ITR 484 were duly explained after referring to further developments in various judgments, it was held that whether satisfaction existed and was not recorded during assess-ment was not a matter of form but of substance and the absence of satisfaction could not be inferred from t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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