https://www.taxtmi.com/caselaws?id=797005 Penalty proceedings for concealment under section 271(1)(c) require the Assessing Officer to record satisfaction during assessment proceedings, forming the jurisdictional basis for initiation. The deeming provision in section 271(1B) applies only where an assessment or reassessment contains an addition or disallowance and a clear direction to initiate penalty. Where reassessment accepts the returned income without adjustment, a statement that penalty proceedings will be initiated separately is merely prospective and does not establish present satisfaction. Notices issued under section 274 only after assessment completion cannot remedy invalid initiation. Explanation 5A may deem concealment for penalty purposes but does not cure the absence of valid jurisdictional initiation. en-us Thu, 06 Aug 2026 00:00:00 +0530 Fri, 14 Aug 2026 07:18:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797005 Penalty proceedings for concealment under section 271(1)(c) require the Assessing Officer to record satisfaction during assessment proceedings, forming the jurisdictional basis for initiation. The deeming provision in section 271(1B) applies only where an assessment or reassessment contains an addition or disallowance and a clear direction to initiate penalty. Where reassessment accepts the returned income without adjustment, a statement that penalty proceedings will be initiated separately is merely prospective and does not establish present satisfaction. Notices issued under section 274 only after assessment completion cannot remedy invalid initiation. Explanation 5A may deem concealment for penalty purposes but does not cure the absence of valid jurisdictional initiation. Case-Laws Income Tax Thu, 06 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797005