2007 (9) TMI 673

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....on 260(A) of the Income Tax Act, 1961('Act') is directed against the order dated 22nd November, 2005 passed by the Income Tax Appellate Tribunal('Tribunal') Delhi Bench ?G?, New Delhi in ITA No.1968/Del./2005 for the assessment year 1996-97. By the impugned order, the Tribunal allowed the appeal filed by the Assessee challenging the levy of penalty under Section 271(1)(c) of the Ac....

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....d the following substantial question of law to a larger Bench which according to the referring Bench was not considered in Ram Commercial Enterprises Limited: Whether satisfaction of the officer initiating the proceedings under section 271 of the Income-tax Act can be said to have been recorded even in cases where satisfaction is not recorded in specific terms but is otherwise discernible from or....

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....ted in the assessment order. In that event the assessment order in the present case would have to be examined to find out if the satisfaction of the Assessing Officer is discernible. Therefore, without expressing any view on the issue pending consideration by the larger Bench, and presuming that the question referred to it is answered in the affirmative, we proceed to examine the assessment order....