Statutory refund interest requires correction of short computation and compensation where admitted interest remains unpaid through administrative dela...
Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
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The ITAT held that the penalty under section 271(1)(c) was unsustainable as the Assessing Officer failed to record satisfaction specifically whether the assessee concealed particulars of income or furnished inaccurate particulars, a mandatory precondition for initiating penalty proceedings. The AO issued the notice under section 274 read with section 271(1)(c) in a standard proforma without deleting irrelevant portions, indicating non-application of mind. Consequently, the penalty notice was invalid for lack of clarity and specificity, denying the assessee adequate opportunity to respond. The tribunal quashed the penalty order, allowing the appeal, reaffirming that proper satisfaction and clear specification of charge are essential prerequisites before imposing penalty under section 271(1)(c).
The ITAT held that the penalty under section 271(1)(c) was unsustainable as the Assessing Officer failed to record satisfaction specifically whether the assessee concealed particulars of income or furnished inaccurate particulars, a mandatory precondition for initiating penalty proceedings. The AO issued the notice under section 274 read with section 271(1)(c) in a standard proforma without deleting irrelevant portions, indicating non-application of mind. Consequently, the penalty notice was invalid for lack of clarity and specificity, denying the assessee adequate opportunity to respond. The tribunal quashed the penalty order, allowing the appeal, reaffirming that proper satisfaction and clear specification of charge are essential prerequisites before imposing penalty under section 271(1)(c).
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