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2007 (12) TMI 97 - ANDHRA PRADESH HIGH COURT
AO has to form his own opinion & record his satisfaction, of concealment of income or furnishing of inaccurate particulars of income, before initiating penalty proceedings u/s 271(1)(c) – assessment was completed accepting the returned net income as per the revised return – both assessment order & SCN are silent about such satisfaction of AO - Nothing has been placed by Revenue to show that any other material was available with AO to confirm concealment – penalty set aside