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The HC held that penalty under s.271(1)(c) could not be sustained where the AO failed to form the requisite subjective satisfaction that the assessee concealed particulars of income or furnished inaccurate particulars. The AO's ad-hoc estimation limiting profit in purchases to 12.5% and implicit acceptance of sales invoices precluded a finding of deliberate concealment or fabrication of records. Because penalty provisions are penal and require strict construction, initiation of penalty proceedings based solely on re-opening additions without clear material demonstrating intentional concealment was impermissible. The appeal of the assessee was allowed and the penalty under s.271(1)(c) was set aside.
The HC held that penalty under s.271(1)(c) could not be sustained where the AO failed to form the requisite subjective satisfaction that the assessee concealed particulars of income or furnished inaccurate particulars. The AO's ad-hoc estimation limiting profit in purchases to 12.5% and implicit acceptance of sales invoices precluded a finding of deliberate concealment or fabrication of records. Because penalty provisions are penal and require strict construction, initiation of penalty proceedings based solely on re-opening additions without clear material demonstrating intentional concealment was impermissible. The appeal of the assessee was allowed and the penalty under s.271(1)(c) was set aside.
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