In the result, the appeals of the assessees for all the
Bench: Shri Abraham P. George]
penalty under section 271(1) ( c) Income-tax Act, even while giving opportunity to the petitioner in proceedings dated February 10, 2005, to submit their objections on or before February, 2005, with regard to reopening of the assessment for the assessment year 2001-01 and before deciding the matter on the merits. The notices of reassessment as well as consequential