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Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma
penalty proceedings u/s 271(1)(c) are initiated separately’ do not comply with the meaning of the word ‘direction’ as contemplated in amended section 271(1B) of the Act. 9.2.8 In view of the above judicial pronouncements, both pre and post insertion of S. 271(1B), the position of law emerges is that for initiation of I.T.As No.2631/Del/2018