https://www.taxtmi.com/caselaws?id=423805 Penalty under section 271(1)(c) requires a clear recorded satisfaction in the assessment order as to the specific limb of default, namely concealment of income or furnishing of inaccurate particulars; absent such satisfaction, the levy is unsustainable. The note also states that an appellate authority dealing with a penalty appeal cannot direct fresh initiation of penalty proceedings under section 271AAA for the same addition, because its powers are limited to confirming, reducing, enhancing, or cancelling the penalty. On both points, the penalty was deleted and the direction to commence proceedings under another provision was treated as beyond jurisdiction. en-us Mon, 13 Jun 2022 00:00:00 +0530 Tue, 14 Jun 2022 14:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=423805 Penalty under section 271(1)(c) requires a clear recorded satisfaction in the assessment order as to the specific limb of default, namely concealment of income or furnishing of inaccurate particulars; absent such satisfaction, the levy is unsustainable. The note also states that an appellate authority dealing with a penalty appeal cannot direct fresh initiation of penalty proceedings under section 271AAA for the same addition, because its powers are limited to confirming, reducing, enhancing, or cancelling the penalty. On both points, the penalty was deleted and the direction to commence proceedings under another provision was treated as beyond jurisdiction. Case-Laws Income Tax Mon, 13 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=423805