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    <title>2019 (1) TMI 1403 - ITAT AMRITSAR</title>
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    <description>Penalty under section 271(1)(c) was held unsustainable because the Principal Commissioner&#039;s revisional order did not record clear satisfaction that the assessee had furnished inaccurate particulars of income. Section 271(1B) was held to cure only cases where penalty is initiated by an Assessing Officer, and not where initiation is by a Principal Commissioner, who is outside the definition of Assessing Officer under section 2(7A). In the absence of the requisite recorded satisfaction, the initiation of penalty suffered from a jurisdictional defect and was quashed in favour of the assessee, with the same reasoning applied to the connected assessment years.</description>
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      <description>Penalty under section 271(1)(c) was held unsustainable because the Principal Commissioner&#039;s revisional order did not record clear satisfaction that the assessee had furnished inaccurate particulars of income. Section 271(1B) was held to cure only cases where penalty is initiated by an Assessing Officer, and not where initiation is by a Principal Commissioner, who is outside the definition of Assessing Officer under section 2(7A). In the absence of the requisite recorded satisfaction, the initiation of penalty suffered from a jurisdictional defect and was quashed in favour of the assessee, with the same reasoning applied to the connected assessment years.</description>
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