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    <title>2005 (6) TMI 233 - ITAT DELHI-G</title>
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    <description>The Court held that penalties were not validly initiated in the cases at hand due to the lack of recorded satisfaction by the Assessing Officer in accordance with the law. The Tribunal upheld this decision, canceling the penalty orders passed by the Assessing Officer and allowing the appeals of the assessees. The argument that the judgment of the High Court was per incuriam was rejected by the Tribunal, which clarified that the High Court&#039;s decision did not ignore relevant statutory provisions or binding authorities, and there was no conflict with the Supreme Court judgment.</description>
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