https://www.taxtmi.com/caselaws?id=199483 For penalty under the Income Tax Act, 1922, the requisite statutory satisfaction must be formed during the assessment proceedings themselves, and a contemporaneous assessment record noting clear default was sufficient to meet that timing requirement. The later date of the penalty order did not invalidate the satisfaction already recorded. On notice and hearing, the assessee's own letters acknowledging receipt of notice under the penalty provision and asking for time to explain showed that notice had been served and an opportunity to respond was available. The challenge to penalty on both grounds therefore failed, and the penalty order as reduced in revision was left undisturbed. en-us Wed, 18 Sep 1957 00:00:00 +0530 Thu, 01 Mar 2018 14:48:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=199483 For penalty under the Income Tax Act, 1922, the requisite statutory satisfaction must be formed during the assessment proceedings themselves, and a contemporaneous assessment record noting clear default was sufficient to meet that timing requirement. The later date of the penalty order did not invalidate the satisfaction already recorded. On notice and hearing, the assessee's own letters acknowledging receipt of notice under the penalty provision and asking for time to explain showed that notice had been served and an opportunity to respond was available. The challenge to penalty on both grounds therefore failed, and the penalty order as reduced in revision was left undisturbed. Case-Laws Income Tax Wed, 18 Sep 1957 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=199483