2018 (6) TMI 1554

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....der Kaur, CIT-DR ORDER Per Sanjay Arora, AM: This is a set of four Appeals by two Assessees for two consecutive years, i.e., assessment years (AYs.) 2008-09 and 2009-10. The same raising common issues, were taken up for hearing by the Tribunal together, i.e., on 26/8/2015. However, a difference of opinion on the sustainability of the penalty u/s. 271(1)(c) of the Income Tax Act, 1961 ('th....

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....o members: "Whether, in case where the satisfaction of the AO while initiating penalty proceedings u/s. 271(1)(c) of the Income Tax Act, 1961 is with regard to alleged concealment of income by the assessee, whereas the imposition of the penalty is for 'concealment/furnishing inaccurate particulars of income', the levy of penalty is not sustainable?" 2. The ld. third member has in terms of sec. ....