In the result, the appeal of the assessee is allowed
Bench: the disposal of the same.
274 read with section 271(1)(c). On careful examination of the assessment order and the penalty order, we find that the Assessing Officer has recorded a clear and categorical satisfaction that the assessee had furnished inaccurate particulars of income in respect of the disallowance under section 40(a)(ia) as well as excess depreciation claimed. The penalty order unequivocally