Assessing Officer Must Independently Justify Penalty u/s 271(1)(b) Separate from Tax Assessment Proceedings.

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....Levy of penalty u/s 271(1)(b) - It is a settled position that assessment and penalty proceedings are two separate and distinct proceedings and though reference can be drawn to the findings in the assessment order, the AO has to record independent findings as to why penalty may be levied in the given case - AT....