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2018 (11) TMI 1605 - AT - Income TaxPenalty u/s 271(1)(c) - AO nowhere recoded under which limb as prescribed 271(1)(c) the satisfaction has been made. unexplained credits in his bank account - HELD THAT:- Satisfaction must be there either directly or indirectly and while levying the penalty A.O. must be sure under which limb, he is levying the penalty and it is trite that penalty cannot be levied for twin charges until and unless the satisfaction recorded under both the limbs separately and followed with correct notice u/s 274 of the Act, specifying exact limbs, because the penalty for furnishing of inaccurate particulars and concealment of particulars of income are all altogether mutually different connotation which is settled by the various Courts, hence, we do not have any hesitation to delete the penalty being illegal and unjustified. - Decided in favour of assessee.
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