https://www.taxtmi.com/caselaws?id=753543 The ITAT Raipur held that penalty proceedings under Section 270A for under-reporting of income were invalid due to the AO's failure to record proper satisfaction regarding concealment of income or inaccurate particulars furnished by the assessee. Following the SC precedent in Golden Peace Hotels and Resorts, the tribunal found that without specific satisfaction being recorded in the assessment order, or where satisfaction references both limbs (under-reporting and mis-reporting) without specifying the relevant limb, the penalty proceedings are erroneous and arbitrary. The penalties imposed on disallowance of cost of improvement and HRA claim were consequently deleted, with the decision favoring the assessee. en-us Fri, 31 May 2024 00:00:00 +0530 Wed, 05 Jun 2024 08:16:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753543 The ITAT Raipur held that penalty proceedings under Section 270A for under-reporting of income were invalid due to the AO's failure to record proper satisfaction regarding concealment of income or inaccurate particulars furnished by the assessee. Following the SC precedent in Golden Peace Hotels and Resorts, the tribunal found that without specific satisfaction being recorded in the assessment order, or where satisfaction references both limbs (under-reporting and mis-reporting) without specifying the relevant limb, the penalty proceedings are erroneous and arbitrary. The penalties imposed on disallowance of cost of improvement and HRA claim were consequently deleted, with the decision favoring the assessee. Case-Laws Income Tax Fri, 31 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753543