2002 (12) TMI 75

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....al under section 260A of the Income-tax Act, 1961, has been filed against the impugned order of the Income-tax Appellate Tribunal dated August 31, 2000. The case relates to penalty under section 273(2)(a) of the Act for allegedly furnishing a false estimate of advance tax. Only one point has been pressed by learned counsel for the appellant. He submitted that before issuing notice for initiating ....

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....ason for doing so". Section 273 does not have a similar provision requiring recording the reason or satisfaction. Hence, it has to be inferred that Parliament never intended that before initiating penalty proceedings and issuing notice under section 273, the Assessing Officer must record his reasons in writing for doing so. Had that been so there would have been a specific mention about it in sect....