Assessing Officer Must Specify Invoked Provision for Penalties u/s 271(1)(C) of Income Tax Act, Rules High Court.

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....Penalty u/s 271(1)(C) - manadation of recording satisfaction which limb of the provisions of Section 271(1)(c) of the Act was triggered - In a given case, both limbs may get attracted, but even in such situation the AO would need to set forth his prima facie, satisfaction in the penalty notice. - HC....