https://www.taxtmi.com/caselaws?id=423805 Penalty under section 271(1)(c) requires the assessment order to record clear satisfaction whether the alleged default is concealment of income or furnishing inaccurate particulars. Where an addition arises from disallowance of deferred revenue expenditure and no specific limb is recorded, a mere difference of opinion cannot sustain the penalty; the penalty was cancelled. In an appeal against a penalty order, the Commissioner (Appeals) may confirm, cancel, enhance, or reduce the penalty but cannot direct fresh penalty proceedings under section 271AAA. The direction to issue such notice for the same addition exceeded appellate jurisdiction and was invalid. 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 the assessment order to record clear satisfaction whether the alleged default is concealment of income or furnishing inaccurate particulars. Where an addition arises from disallowance of deferred revenue expenditure and no specific limb is recorded, a mere difference of opinion cannot sustain the penalty; the penalty was cancelled. In an appeal against a penalty order, the Commissioner (Appeals) may confirm, cancel, enhance, or reduce the penalty but cannot direct fresh penalty proceedings under section 271AAA. The direction to issue such notice for the same addition exceeded appellate jurisdiction and was invalid. Case-Laws Income Tax Mon, 13 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=423805