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The additional ground is admitted. The contention of the revenue is that misquoting of section will not affect the merits of the case. In our view, this is not a case of mis-quoting of section or sub-section. This is a case in which in the course of assessment proceedings, the Income-tax Officer has reached the satisfaction only for imposing penalty under Section 273(2)(a) but not under Section 273(2)(aa) of the Income-tax Act as will be clear from the assessment order itself. There can be a mis-quoting of the section in the order imposing penalty. Such mis-quoting of section is indefensible if it had occurred at the stage of reaching the satisfaction to impose penalty, as such satisfaction must be in relation to the particular default that was committed and the particular provision under which the default was to be penalised. On a perusal of the assessment order there can be no two opinion that the satisfaction was reached by the Income-tax Officer only in respect of an offence inviting penalty under Section 273(2)(a) of the Income-tax Act.