https://www.taxtmi.com/caselaws?id=254052 Penalty proceedings for concealment of income or furnishing inaccurate particulars require the Assessing Officer's satisfaction to arise during assessment. Section 271(1B) deems such satisfaction where the assessment order contains a direction to initiate penalty proceedings. Where the assessment order contains no indication of initiation or recorded satisfaction, initiation is untenable. Acceptance of additions or payment of tax does not cure that defect or independently justify penalty. A later Supreme Court decision cited by the Revenue does not alter this position where it did not address an assessment order silent on penalty initiation. Consequently, penalty cannot be sustained without the requisite assessment-order endorsement. 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 for concealment of income or furnishing inaccurate particulars require the Assessing Officer's satisfaction to arise during assessment. Section 271(1B) deems such satisfaction where the assessment order contains a direction to initiate penalty proceedings. Where the assessment order contains no indication of initiation or recorded satisfaction, initiation is untenable. Acceptance of additions or payment of tax does not cure that defect or independently justify penalty. A later Supreme Court decision cited by the Revenue does not alter this position where it did not address an assessment order silent on penalty initiation. Consequently, penalty cannot be sustained without the requisite assessment-order endorsement. Case-Laws Income Tax Tue, 11 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=254052