Penalty u/s 270A requires AO to record satisfaction about concealment or inaccurate particulars. Penalties imposed without proper satisfaction are invalid.

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....The Appellate Tribunal held that for penalty u/s 270A, there must be satisfaction by the AO about concealment of income or inaccurate particulars. Citing Golden Peace Hotels and Resorts case, without such satisfaction, penalty proceedings are invalid. The penalty imposed on capital gain without AO's satisfaction in the original assessment order was deemed erroneous. Penalties imposed without specifying the relevant reason for underreporting or misreporting are arbitrary and lack merit. Therefore, the penalties imposed by the jurisdictional AO u/s 270A were not approved. The decision favored the assessee.....