Jurisdictional satisfaction for concealment penalty cannot be created later by substituting a distinct penal provision after assessment.

Jurisdictional satisfaction for concealment penalty cannot be created later by substituting a distinct penal provision after assessment. https://www.taxtmi.com/highlights?id=104586 Jurisdictional satisfaction for penalty under section 271(1)(c) must be recorded during assessment, including a direction to initiate penalty under that provision where deemed satisfaction is invoked. Initiation under section 271AAC, a distinct provision with separate conditions and consequences, cannot support a later notice or penalty under section 271(1)(c). A subsequent penalty order cannot amend the assessment order or retrospectively create foundational jurisdiction. The penalty was therefore deleted, while the quantum appeal remained for independent determination on merits. en-us Tue, 06 Oct 2026 08:13:52 +0530 Tue, 06 Oct 2026 08:13:54 +0530 TaxTMI RSS Generator Jurisdictional satisfaction for concealment penalty cannot be created later by substituting a distinct penal provision after assessment. https://www.taxtmi.com/highlights?id=104586 Jurisdictional satisfaction for penalty under section 271(1)(c) must be recorded during assessment, including a direction to initiate penalty under that provision where deemed satisfaction is invoked. Initiation under section 271AAC, a distinct provision with separate conditions and consequences, cannot support a later notice or penalty under section 271(1)(c). A subsequent penalty order cannot amend the assessment order or retrospectively create foundational jurisdiction. The penalty was therefore deleted, while the quantum appeal remained for independent determination on merits. Highlights Income Tax Tue, 06 Oct 2026 08:13:52 +0530 https://www.taxtmi.com/highlights?id=104586