https://www.taxtmi.com/caselaws?id=759572 The ITAT Patna quashed penalties levied under sections 271(1)(c) and 271AAA of the Income Tax Act. The AO imposed penalties solely based on ITSC's withdrawal of immunity from penalty and prosecution, without following proper procedural requirements. For section 271(1)(c), the AO failed to record satisfaction regarding concealment of income or furnishing inaccurate particulars, issued no notice under section 274, and conducted no proper assessment proceedings. The penalty was deemed arbitrary and void ab initio. For section 271AAA penalties, the AO did not fulfill prescribed conditions, record statements under section 132(4), or ask the assessee to explain undisclosed income sources, rendering the proceedings illegal and void. en-us Mon, 30 Sep 2024 00:00:00 +0530 Fri, 04 Oct 2024 08:19:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759572 The ITAT Patna quashed penalties levied under sections 271(1)(c) and 271AAA of the Income Tax Act. The AO imposed penalties solely based on ITSC's withdrawal of immunity from penalty and prosecution, without following proper procedural requirements. For section 271(1)(c), the AO failed to record satisfaction regarding concealment of income or furnishing inaccurate particulars, issued no notice under section 274, and conducted no proper assessment proceedings. The penalty was deemed arbitrary and void ab initio. For section 271AAA penalties, the AO did not fulfill prescribed conditions, record statements under section 132(4), or ask the assessee to explain undisclosed income sources, rendering the proceedings illegal and void. Case-Laws Income Tax Mon, 30 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759572