Penalty u/s 271(1)(c) - There is no prima facie satisfaction which has been recorded by the AO for...

Penalty u/s 271(1)(c) - There is no prima facie satisfaction which has been recorded by the AO for initiation of penalty proceedings which can be discerned from reading of the assessment order. - Addition has been made, merely, on a presumptive basis which is not sufficient for acquiring jurisdiction as contemplated by the provisions of section 271(1B) - AT .....

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