In the result, this appeal filed by the assessee is allowed
Bench: Shri Partha Sarathi Chaudhury & Shri Ratnesh Nandan Sahay
46,176/- 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. ITA No. 84 to 86/Ran/2022 Gajanan Ferro