Penalty u/s 271(1)(c) Requires Assessing Officer's Satisfaction; Acceptance of Addition Alone Insufficient for Penalty.

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....Levy of penalty u/s 271(1)(c) - The Assessing Officer has to record satisfaction before initiating penalty proceedings and the penalty proceedings are subject to judicial scrutiny independent of additions/disallowances made under assessment proceedings. Therefore, levy of penalty for the reason that the addition/disallowance has been accepted by the assessee is not sustainable ground - AT....