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2019 (1) TMI 961
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....ounsel Along With Sri: M. Lava, Advocate For the Respondent : K.V. Aravind, Advocate JUDGMENT These appeals were admitted on 25.07.2012 to consider the following substantial questions of law: "1. Whether it is mandatory for the Assessing Officer to state the reasons and note his satisfaction on record in the assessment order for initiating penalty proceedings, if not don....
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..... The learned Counsel submits that the questions of law requires to be re-framed. That they have addressed arguments on the same. Hence, the question of law are re-framed and the following substantial question of law is framed for consideration in these appeals. "Whether the levy of penalty under Section 271(1)(c) of the Act is sustainable in law when the notice issued under Section 274 o....