https://www.taxtmi.com/caselaws?id=254052 Penalty proceedings under section 271(1)(c) of the Income-tax Act require the Assessing Officer's satisfaction to arise during assessment and be reflected by an endorsement or direction in the assessment order. Section 271(1B) deems such satisfaction only where the order contains initiation of penalty proceedings; where the assessment order is silent, initiation is untenable. The article notes that the Revenue cannot sustain penalty merely because the assessee accepted additions or paid tax, and that a later Supreme Court decision does not assist where it did not address a silent assessment order. The operative effect is that penalty initiation fails for want of recorded satisfaction. en-us Tue, 11 Nov 2014 00:00:00 +0530 Thu, 19 Feb 2026 13:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=254052 Penalty proceedings under section 271(1)(c) of the Income-tax Act require the Assessing Officer's satisfaction to arise during assessment and be reflected by an endorsement or direction in the assessment order. Section 271(1B) deems such satisfaction only where the order contains initiation of penalty proceedings; where the assessment order is silent, initiation is untenable. The article notes that the Revenue cannot sustain penalty merely because the assessee accepted additions or paid tax, and that a later Supreme Court decision does not assist where it did not address a silent assessment order. The operative effect is that penalty initiation fails for want of recorded satisfaction. Case-Laws Income Tax Tue, 11 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=254052