In the result, all the captioned appeals of the assessee for A
Bench: Dr. Manish Borad, Am & Shri Sonjoy Sarma, Jm
183 TAXMAN 100 (DELHI)] held as under: - “in this case it was held that "an assessment order should contain at least a direction for initiation of penalty proceedings to constitute satisfaction of the AO for initiation of penalty proceedings under Section 271(1)(c). Even post Section 271(18), still a prima facie satisfaction of Assessing Officer that the case