Penalty Invalid if Assessing Officer Fails to Record Satisfaction u/s 271(1)(c); Not Correctable by Section 292B.

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....Levy of penalty levied u/s 271(1)(c) - The failure of the Assessing Officer to record such satisfaction makes the order levying penalty invalid and bad in law and such mistake is not curable defect under section 292B of the Act as it goes to the jurisdiction of levy of penalty for concealment. - AT....