https://www.taxtmi.com/caselaws?id=178654 HC upheld the Tribunal's deletion of penalty u/s 271(1)(c), holding that the AO had treated penalty as an automatic consequence of concealment or furnishing of inaccurate particulars without recording specific satisfaction or reasons justifying initiation of penalty proceedings. The AO failed to state why penalty was "just and proper" or why the assessee's immediate surrender was not bona fide or voluntary. Relying on settled precedent that recording of proper satisfaction is a sine qua non for valid penalty, HC found no substantial question of law and dismissed the revenue's appeal in limine. en-us Fri, 14 Jan 2005 00:00:00 +0530 Wed, 10 Dec 2025 13:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178654 HC upheld the Tribunal's deletion of penalty u/s 271(1)(c), holding that the AO had treated penalty as an automatic consequence of concealment or furnishing of inaccurate particulars without recording specific satisfaction or reasons justifying initiation of penalty proceedings. The AO failed to state why penalty was "just and proper" or why the assessee's immediate surrender was not bona fide or voluntary. Relying on settled precedent that recording of proper satisfaction is a sine qua non for valid penalty, HC found no substantial question of law and dismissed the revenue's appeal in limine. Case-Laws Income Tax Fri, 14 Jan 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178654