Penalty order u/s 272A(1)(d) - No co-operation from assessee's...

Penalty order u/s 272A(1)(d) - No co-operation from assessee's side - To the mind of this Bench, ‘non-cooperative attitude’ as such in itself cannot be the basis of imposing penalty under the relevant section, as above, without specifically bringing on record the specific notices, their specific non-compliances and the satisfaction of the ld. AO recorded during the assessment proceedings that there has been failure to comply with the said notice for which imposing penalty is warranted. - AT