In the result, this appeal filed by the assessee is allowed
Bench: Shri Partha Sarathi Chaudhury & Shri Ratnesh Nandan Sahay
160/- needs to be quashed. 2. That the very initiation of penalty is bad in law as the Ld. AO has failed to record a proper or transparent satisfaction in his notice while initiating proceedings under section 271(1)(c), thus rendering the entire penalty proceedings null and void. 3. That under the facts and circumstances, the initiation of penalty