https://www.taxtmi.com/caselaws?id=11730 Penalty under s. 271(1)(c) was held unsustainable because the jurisdiction to levy penalty arises only from the Assessing Officer's contemporaneous recording of a clear and valid satisfaction in the assessment proceedings that the assessee concealed income or furnished inaccurate particulars; such satisfaction cannot be presumed merely from issuance of a notice or a general initiation remark, and a jurisdictional defect is incurable. Applying SC and HC precedents on the mandatory nature of satisfaction for assuming penalty jurisdiction, the HC found the Tribunal's view legally correct and that no substantial question of law arose under s. 260A. The revenue appeal was dismissed and cancellation of penalty upheld. en-us Tue, 22 Apr 2003 00:00:00 +0530 Sun, 28 Dec 2025 22:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=11730 Penalty under s. 271(1)(c) was held unsustainable because the jurisdiction to levy penalty arises only from the Assessing Officer's contemporaneous recording of a clear and valid satisfaction in the assessment proceedings that the assessee concealed income or furnished inaccurate particulars; such satisfaction cannot be presumed merely from issuance of a notice or a general initiation remark, and a jurisdictional defect is incurable. Applying SC and HC precedents on the mandatory nature of satisfaction for assuming penalty jurisdiction, the HC found the Tribunal's view legally correct and that no substantial question of law arose under s. 260A. The revenue appeal was dismissed and cancellation of penalty upheld. Case-Laws Income Tax Tue, 22 Apr 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=11730