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2015 (3) TMI 497 - ALLAHABAD HIGH COURTPenalty u/s 271(1)(c) - whether Assessing Officer has not recorded any positive and categorical satisfaction about concealment in the assessment order? - ITAT deleted penalty levy - Held that:- What is required in law is satisfaction of assessing officer which should be apparent from the order, regarding concealment of particulars of income or furnishing of inaccurate particulars of such income. The provisions of section 271(1)(c) are penal in nature, thus must be strictly construed, and the element of satisfaction should be apparent from the order itself. It is not for the courts to go into the mind of the authorities or trace the reasons from the file of such authorities. - Decided in favour of assessee
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