AO's Failure to Record Satisfaction Invalidates Penalty Proceedings u/s 271(1)(c) for Inaccurate Income Reporting.

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....AO did not record his satisfaction for initiation of penalty proceedings, because while passing the assessment order passed u/s. 143(3)(ii), the AO has stated that “….. Penalty proceedings u/s. 271(1)(c)is being initiated separately for furnishing inaccurate particulars of income / concealment income……………….”, which is not sufficient - AT....