https://www.taxtmi.com/caselaws?id=786110 Penalty under tax law was set aside because the original addition that triggered penalty proceedings was deleted on appeal and the amount ultimately sustained arose from appellate recharacterisation. The Assessing Officer failed to record a fresh, specific satisfaction of concealment or inaccurate particulars after the appellate outcome; the penalty order merely applied consequential figures mechanically. Where primary facts were disclosed in the return and dispute concerns legal characterisation or head of income, concealment is not established; absent the required satisfaction, quasicriminal penalty cannot be sustained and the appeal was allowed. en-us Tue, 27 Jan 2026 00:00:00 +0530 Fri, 06 Feb 2026 09:25:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786110 Penalty under tax law was set aside because the original addition that triggered penalty proceedings was deleted on appeal and the amount ultimately sustained arose from appellate recharacterisation. The Assessing Officer failed to record a fresh, specific satisfaction of concealment or inaccurate particulars after the appellate outcome; the penalty order merely applied consequential figures mechanically. Where primary facts were disclosed in the return and dispute concerns legal characterisation or head of income, concealment is not established; absent the required satisfaction, quasicriminal penalty cannot be sustained and the appeal was allowed. Case-Laws Income Tax Tue, 27 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786110