Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
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The Appellate Tribunal considered the issue of penalty u/s 271(1)(c) of the Act. It was questioned whether a precise charge was brought against the assessee and if the assessing officer had recorded proper satisfaction. The assessee offered additional income during a search related to inflated marketing expenses. The Tribunal found that the assessing officer did not specify the charge in the penalty proceedings notice, rendering the initiation of penalty proceedings invalid. The vague notice issued was deemed void, leading to the penalty order being quashed in favor of the assessee.
The Appellate Tribunal considered the issue of penalty u/s 271(1)(c) of the Act. It was questioned whether a precise charge was brought against the assessee and if the assessing officer had recorded proper satisfaction. The assessee offered additional income during a search related to inflated marketing expenses. The Tribunal found that the assessing officer did not specify the charge in the penalty proceedings notice, rendering the initiation of penalty proceedings invalid. The vague notice issued was deemed void, leading to the penalty order being quashed in favor of the assessee.
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