Penalty u/s 271(1)(c) - There was the need for the AO to record the clear satisfaction with respect to...

Penalty u/s 271(1)(c) - There was the need for the AO to record the clear satisfaction with respect to each addition/disallowances made during the assessment proceedings for initiating the penalty. Accordingly, in the absence of necessary satisfaction of the AO, we hold that the penalty order is not sustainable. - AT .....

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