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    <title>2016 (5) TMI 544 - ITAT KOLKATA</title>
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    <description>The Tribunal held that the penalty under Section 271(1)(c) was unsustainable due to the lack of proper satisfaction recording in the assessment order and the defective show cause notice under Section 274. Consequently, the orders imposing penalty were cancelled, and the appeals by the assessee were allowed, while the appeals by the revenue were dismissed. The ruling emphasized the importance of clear and specific charges in penalty proceedings and the necessity of proper satisfaction recording by the AO.</description>
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      <title>2016 (5) TMI 544 - ITAT KOLKATA</title>
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      <description>The Tribunal held that the penalty under Section 271(1)(c) was unsustainable due to the lack of proper satisfaction recording in the assessment order and the defective show cause notice under Section 274. Consequently, the orders imposing penalty were cancelled, and the appeals by the assessee were allowed, while the appeals by the revenue were dismissed. The ruling emphasized the importance of clear and specific charges in penalty proceedings and the necessity of proper satisfaction recording by the AO.</description>
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