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2020 (4) TMI 397 - ITAT DELHIPenalty levied u/s 271(1)(c) - Credit capital account with the narration ‘Gift received’ - HELD THAT:- AO has not recorded any satisfaction as to which limb of section 271(1)(c) of the Act has not been fulfilled and have not issued show cause notice in this regard and hence, initiation of penalty proceedings are bad in law. We find no merit in the levy of penalty under section 271(1)(c) of the Act where the initiation of penalty proceedings is without recording of satisfaction. Accordingly, we delete the same. Hence, grounds of appeal raised by the assessee are allowed.
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