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of Penalty u/s 271(1)(c) - fresh assessment in the remand proceedings - AO not only maintained the earlier income but even the appeal instituted by the appellant against the same was withdrawn by the appellant. In such circumstances, we are unable to agree with the contentions of the appellant that at the stage of making order giving effect to the Order of the Commissioner (Appeals), there was necessity of making a fresh Order or there was a necessity of issuing a fresh notice for initiating the penalty proceedings.
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