(1.) 105/Del/2005 relevant for the asst. yr. 1998 -99.
(2.) Relying upon a decision of this Court in CIT vs. Ram Commercial Enterprises Ltd. (2001) 167 CTR (Del) 321 : (2000) 246 ITR 568 (Del), the Tribunal struck down the penalty proceedings initiated against the assessee on the ground that there was no satisfaction of the AO recorded holding that the penalty proceeding should be initiated against the assessee.
(3.) We find that the decision of this Court in Ram Commercial Enterprises Ltd.'s case (supra) has been approved by the Supreme Court in Dilip N. Shroff vs. Jt. CIT (2007) 210 CTR (SC) 228 : (2007) 291 ITR 519 (SC) and T. Ashok Pai vs. CIT (2007) 210 CTR (SC) 259 : (2007) 292 ITR 11 (SC).