Sanjay Kumar, J.

1. This appeal by the revenue under Section 260A of the Income-tax Act, 1961 (for brevity, the Act of 1961), relating to the assessment year 2010-11, seeks to raise the following substantial questions of law for consideration:

1. Whether, on the facts and in the circumstances of the case, the Tribunal is correct in law in deleting the penalty levied u/s. 271(1)(c) of the Income-tax Act, 1961?

2. Whether, on the facts and in the circumstances of the case, the Tribunal is correct in deleting the penalty levied u/s. 271(1)(c) by the Assessing officer without taking into consideration provisions of Section 271(1B) of Income-tax Act, 1961 and judicial pronouncement of Honble Supreme Court of India in the case of MAK Data Pvt. Ltd., Vs. CIT, 358 ITR 593, wherein, it was specifically held that the A.O has to satisfy whether penalty proceedings be initiated or not during the assessment proceedings and the A.O is not required to record his satisfaction in a particular manner or reduce it into writing?

2. Facts relevant for the purpose of this order are as under: The respondent-assessee derives income from house property apart from interest on bank deposits. She filed