https://www.taxtmi.com/caselaws?id=9249 The court concluded that the Income-tax Officer (ITO) was justified in issuing the notice under section 274 read with section 271 of the Income-tax Act, 1961, as he had formed a tentative belief that the penalty would exceed Rs. 1,000 based on evidence during assessment proceedings. The court found that the procedural requirements under sections 271 and 274 were met, and the ITO did not need to expressly record his satisfaction in writing before issuing the notice. Consequently, the application was dismissed, and the rule discharged with no order as to costs. en-us Fri, 12 Jan 1973 00:00:00 +0530 Sat, 20 Jun 2009 16:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=9249 The court concluded that the Income-tax Officer (ITO) was justified in issuing the notice under section 274 read with section 271 of the Income-tax Act, 1961, as he had formed a tentative belief that the penalty would exceed Rs. 1,000 based on evidence during assessment proceedings. The court found that the procedural requirements under sections 271 and 274 were met, and the ITO did not need to expressly record his satisfaction in writing before issuing the notice. Consequently, the application was dismissed, and the rule discharged with no order as to costs. Case-Laws Income Tax Fri, 12 Jan 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=9249