https://www.taxtmi.com/caselaws?id=7852 The court found the penalty proceedings initiated under Section 271(1)(c) of the Income-tax Act, 1961 to be invalid due to lack of compliance with statutory requirements. It emphasized that the satisfaction necessary for imposing penalties must be formed by the Inspecting Assistant Commissioner before completion of assessment proceedings. The court held that satisfaction and penalty imposition functions must be performed by the same authority. Consequently, the court granted reliefs by recalling, canceling, and withdrawing the notice issued by the Inspecting Assistant Commissioner and issued writs of mandamus and prohibition against further action based on the notice. en-us Fri, 17 Jul 1970 00:00:00 +0530 Mon, 23 Mar 2009 09:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7852 The court found the penalty proceedings initiated under Section 271(1)(c) of the Income-tax Act, 1961 to be invalid due to lack of compliance with statutory requirements. It emphasized that the satisfaction necessary for imposing penalties must be formed by the Inspecting Assistant Commissioner before completion of assessment proceedings. The court held that satisfaction and penalty imposition functions must be performed by the same authority. Consequently, the court granted reliefs by recalling, canceling, and withdrawing the notice issued by the Inspecting Assistant Commissioner and issued writs of mandamus and prohibition against further action based on the notice. Case-Laws Income Tax Fri, 17 Jul 1970 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7852