https://www.taxtmi.com/caselaws?id=248146 The Court upheld the decision of the ITAT setting aside the penalty imposed by the Revenue. It was found that the Commissioner did not record satisfaction when making the revisional order, which is necessary for initiating penalty proceedings under Section 271(1)(c) of the Income Tax Act. The Court emphasized that the AO could not independently initiate penalty proceedings without specific direction in the revisional order. Additionally, it was determined that the assessee had a bona fide belief regarding the short term capital gain, leading to the dismissal of the appeal. en-us Tue, 27 May 2014 00:00:00 +0530 Tue, 03 Jun 2014 18:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=248146 The Court upheld the decision of the ITAT setting aside the penalty imposed by the Revenue. It was found that the Commissioner did not record satisfaction when making the revisional order, which is necessary for initiating penalty proceedings under Section 271(1)(c) of the Income Tax Act. The Court emphasized that the AO could not independently initiate penalty proceedings without specific direction in the revisional order. Additionally, it was determined that the assessee had a bona fide belief regarding the short term capital gain, leading to the dismissal of the appeal. Case-Laws Income Tax Tue, 27 May 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=248146