https://www.taxtmi.com/caselaws?id=770622 HC upheld the tribunal and quashed the revisional order directing the AO to initiate penalty proceedings under section 271(1)(c), holding that satisfaction required for imposing penalty must be recorded during the course of assessment proceedings. The AO had recorded satisfaction only for section 271AAB and issued notices under both sections; absence of contemporaneous satisfaction for 271(1)(c) vitiated those proceedings. The revisional authority cannot direct recording of satisfaction after conclusion of proceedings. Decision against the revenue. en-us Mon, 03 Mar 2025 00:00:00 +0530 Mon, 15 Sep 2025 15:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770622 HC upheld the tribunal and quashed the revisional order directing the AO to initiate penalty proceedings under section 271(1)(c), holding that satisfaction required for imposing penalty must be recorded during the course of assessment proceedings. The AO had recorded satisfaction only for section 271AAB and issued notices under both sections; absence of contemporaneous satisfaction for 271(1)(c) vitiated those proceedings. The revisional authority cannot direct recording of satisfaction after conclusion of proceedings. Decision against the revenue. Case-Laws Income Tax Mon, 03 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770622