In the result, this appeal filed by the assessee is allowed
Bench: Shri Partha Sarathi Chaudhury & Shri Ratnesh Nandan Sahay
u/s 271(1)(c) should had been levied, hence, the impugned order levying penalty of Rs. 7,39,160/- 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