Penalty u/s 271(1)(c) invalid without clear satisfaction on concealment or inaccurate particulars, revenue appeal dismissed

SC upheld the HC's decision quashing penalty proceedings under section 271(1)(c). It was found that the Assessing Officer had not properly recorded satisfaction regarding concealment of income or furnishing of inaccurate particulars, which is a mandatory jurisdictional precondition for initiating penalty. In the absence of such recorded satisfaction, the penalty proceedings were held to be invalid and rightly dropped by the lower authorities. The SC declined to interfere, dismissed the revenue's special leave petition, and thereby confirmed the deletion of penalty against the assessee.

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The Supreme Court dismissed the special leave petition without interference with the impugned order. Delay was condoned, and the pending application was disposed of.

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