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Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishraassessment Years: 2011-12 Amitabha Sanyal, Income Tax Officer, 108B, Block-F, New Alipore, Ward – 58(4), Kolkata, Kolkata – 700053 Vs Aayakar Bhawan, (Pan: Aleps2352J) Bamboo Villa, 169, A.J.C. Bose Road, Kolkata - 700014 (Appellant) (Respondent)
penalty of ₹4,56,362/-, being without jurisdiction, illegal and invalid, bad in law, without recording proper satisfaction within the meaning of Section 271 of the Act and without appreciating that the amount of ₹22,95,849/- arising in the hands of the assessee was duly included in the return filed u/s