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In the result, the appeal of the assessee is allowed
Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma
31. At the outset, we have already opined in cross appeal of the Assessee in ITA No. 941/Del/2019 for Assessment Year 2011-12 in question that the necessary ‘satisfaction’ desired under Section 271(1)(c) r.w. Section 271(1B) is clearly absent in the present case. Thus, where the penalty order itself stands quashed for the reasons mentioned in cross