https://www.taxtmi.com/caselaws?id=8931 The High Court of ALLAHABAD ruled in favor of the Commissioner of Income-tax in a case concerning the commencement of penalty proceedings under section 271(1)(c) of the Income-tax Act, 1961. The court emphasized that the Income-tax Officer must be satisfied of income concealment before the assessment proceedings conclude, as per the Supreme Court precedent. It was clarified that while no formal order is required, evidence of the Officer's satisfaction is crucial for valid penalty proceedings. The court rejected the argument that a notice under section 274(1) must be issued during assessment, stating that section 275 only deals with limitation periods, not the initiation of penalty proceedings. en-us Thu, 23 Dec 1971 00:00:00 +0530 Wed, 17 Jun 2009 15:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8931 The High Court of ALLAHABAD ruled in favor of the Commissioner of Income-tax in a case concerning the commencement of penalty proceedings under section 271(1)(c) of the Income-tax Act, 1961. The court emphasized that the Income-tax Officer must be satisfied of income concealment before the assessment proceedings conclude, as per the Supreme Court precedent. It was clarified that while no formal order is required, evidence of the Officer's satisfaction is crucial for valid penalty proceedings. The court rejected the argument that a notice under section 274(1) must be issued during assessment, stating that section 275 only deals with limitation periods, not the initiation of penalty proceedings. Case-Laws Income Tax Thu, 23 Dec 1971 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8931