https://www.taxtmi.com/caselaws?id=38052 Penalty proceedings are treated as initiated in the course of assessment proceedings where the assessment order itself records the Income-tax Officer's satisfaction about concealment and directs issue of notice under section 274. That satisfaction need not be expressed in any particular form and may be inferred from the assessment order and surrounding circumstances. The use of the word "appears" in the penalty notice does not invalidate prior satisfaction already reached during assessment. On that basis, proceedings for penalty were held to have been validly initiated within the meaning of section 275, and the issue was answered in favour of the Revenue. en-us Wed, 14 Jan 1976 00:00:00 +0530 Fri, 02 Apr 2010 17:31:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38052 Penalty proceedings are treated as initiated in the course of assessment proceedings where the assessment order itself records the Income-tax Officer's satisfaction about concealment and directs issue of notice under section 274. That satisfaction need not be expressed in any particular form and may be inferred from the assessment order and surrounding circumstances. The use of the word "appears" in the penalty notice does not invalidate prior satisfaction already reached during assessment. On that basis, proceedings for penalty were held to have been validly initiated within the meaning of section 275, and the issue was answered in favour of the Revenue. Case-Laws Income Tax Wed, 14 Jan 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38052