https://www.taxtmi.com/caselaws?id=235650 Recorded satisfaction in the assessment order is a prerequisite for imposing penalty under section 271(1)(c); absent a categorical finding that the assessee concealed particulars or furnished inaccurate particulars, mere direction to initiate penalty proceedings is insufficient. The statutory deeming fiction in section 271(1B) cannot validate earlier orders because it applies only from a later retrospective date and is inapplicable to assessment orders passed before that date. Applying these principles, penalties for the assessment years in question could not be sustained and the appeals were allowed for the assessee. en-us Mon, 27 Aug 2012 00:00:00 +0530 Thu, 19 Feb 2026 13:06:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=235650 Recorded satisfaction in the assessment order is a prerequisite for imposing penalty under section 271(1)(c); absent a categorical finding that the assessee concealed particulars or furnished inaccurate particulars, mere direction to initiate penalty proceedings is insufficient. The statutory deeming fiction in section 271(1B) cannot validate earlier orders because it applies only from a later retrospective date and is inapplicable to assessment orders passed before that date. Applying these principles, penalties for the assessment years in question could not be sustained and the appeals were allowed for the assessee. Case-Laws Income Tax Mon, 27 Aug 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=235650