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2013 (1) TMI 458 - HC - Income TaxPenalty u/s 271(1)(c) – Concealment of income - Initiation of penalty proceeding - Assessee contended that the penalty proceedings had been initiated by the A.O. without recording his 'satisfaction' in the assessment order in respect of the alleged concealment and furnishing of inaccurate particulars of income Held that:- Following the decision in case of PEAREY LAL AND SONS (EP) LTD. (2008 (9) TMI 142 - PUNJAB AND HARYANA HIGH COURT) A plain reading of the aforesaid provision clearly spells out that wherever an A.O. during the course of assessment or reassessment proceedings records a direction for initiation of penalty proceedings under Clause (c) of sub-section (1) of Section 271, the same shall be deemed to be satisfaction recorded by the A.O. for initiation of penalty proceedings – Remand back to Tribunal
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