https://www.taxtmi.com/caselaws?id=390480 HC upheld the orders of CIT(A) and ITAT deleting penalty u/s 271(1)(c) on the ground that the AO had not properly recorded satisfaction regarding concealment of income or furnishing of inaccurate particulars, which is a sine qua non for valid initiation of penalty proceedings. The penalty notice was in a printed format without striking off inapplicable portions, failing to indicate with clarity whether the allegation was of concealment, furnishing inaccurate particulars, or both, evidencing non-application of mind. Relying on earlier coordinate Bench rulings, the HC held that such defective satisfaction and notice vitiate the penalty proceedings and found no substantial question of law, thereby dismissing the Revenue's appeal. en-us Mon, 11 Nov 2019 00:00:00 +0530 Wed, 10 Dec 2025 12:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=390480 HC upheld the orders of CIT(A) and ITAT deleting penalty u/s 271(1)(c) on the ground that the AO had not properly recorded satisfaction regarding concealment of income or furnishing of inaccurate particulars, which is a sine qua non for valid initiation of penalty proceedings. The penalty notice was in a printed format without striking off inapplicable portions, failing to indicate with clarity whether the allegation was of concealment, furnishing inaccurate particulars, or both, evidencing non-application of mind. Relying on earlier coordinate Bench rulings, the HC held that such defective satisfaction and notice vitiate the penalty proceedings and found no substantial question of law, thereby dismissing the Revenue's appeal. Case-Laws Income Tax Mon, 11 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=390480