https://www.taxtmi.com/caselaws?id=31782 The HC held that penalty proceedings under section 271(1)(c) are invalid where the assessing authority has not recorded or manifested satisfaction that income was concealed or inaccurate particulars were deliberately furnished. The court affirmed that power to impose the penalty depends on the AO's satisfaction during proceedings and such satisfaction must be evident from the order; mere omission of the phrase "I am satisfied" is not necessarily fatal, but absent a clear finding of concealment or deliberate inaccuracy, initiation of penalty proceedings is without jurisdiction. en-us Thu, 27 Nov 2008 00:00:00 +0530 Mon, 10 Nov 2025 15:52:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=31782 The HC held that penalty proceedings under section 271(1)(c) are invalid where the assessing authority has not recorded or manifested satisfaction that income was concealed or inaccurate particulars were deliberately furnished. The court affirmed that power to impose the penalty depends on the AO's satisfaction during proceedings and such satisfaction must be evident from the order; mere omission of the phrase "I am satisfied" is not necessarily fatal, but absent a clear finding of concealment or deliberate inaccuracy, initiation of penalty proceedings is without jurisdiction. Case-Laws Income Tax Thu, 27 Nov 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=31782