2008 (8) TMI 56

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..... ve gone into facts of the case before disposing penalty proceedings – it shall be duty of AO to take into account all the relevant aspects including the materials, if any, already placed by the assessee, and pass a reasoned
Dr. Arijit Pasayat and Dr. Mukundakam Sharma JJ. Soli J. Sorabjee, Senior Advocate (Sanjay Kochar, Sampath, S. Anant, Krishnan Mahajan, Ms. Lakshmi Iyengar and Ms. Sandhya .....

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..... e background of the materials purportedly placed by the assessee before the Assessing Officer. What the High Court has done is to require the Assessing Officer to pass a reasoned order. The High Court was of the view that Tribunal could not have substituted its own reasonings which were required to be recorded by the Assessing Officer. According to the assessee all relevant aspects were placed for .....

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