Penalty u/s 271(1) C

[ishwar hegde]

The AO has issued assessment order and 271 notice on the same date. he has not specifically menchined whether it is a 'conceelment' or  'inacurate perticulars' But as per the section he has to record the reasons before the date of such search(findings) Whether Ao is justified? Ref case cit2006 -280itr 4129del) may be reffered?

AI Summary

Assessment Order and Section 271 Notice Issued Simultaneously: AO Must Record Satisfaction for Penalties. A user raised a query regarding the issuance of an assessment order and a Section 271 notice by the Assessing Officer (AO) on the same date, questioning whether the AO is justified without specifying if the issue is 'concealment' or 'inaccurate particulars.' The concern is whether reasons must be recorded before such findings. In response, it was clarified that under Section 271, penalties can be imposed for either or both offenses if the AO has recorded his satisfaction. A referenced case may provide further guidance on this matter.