In the result, all the appeals filed by the assessee are allowed and copy of common order passed is to be placed on respective case files
Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]
9) The Assessing Officer has to satisfy whether the penalty proceedings be initiated or not during the course of the assessment proceedings and the Assessing Officer is not required to record his satisfaction in a particular manner or reduce it into writing. [Para 10] In view of above, impugned penalty order passed by the High Court deserved to be confirmed