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2016 (4) TMI 992 - AT - Income TaxLevy of penalty u/s 271(1)(c) - Held that:- Assessing Officer has not recorded satisfaction specifically for concealed particulars of income or furnished inaccurate particulars of income and on both. The various courts have held that this satisfaction can be for both the purposes i.e. for concealed particulars of income and furnishing of inaccurate particulars of income jointly as both the satisfaction are overlapping, which is also not found place in the case before us. The Assessing Officer even has not ticked specific satisfaction in notice U/s 274 of the Act. Sending printed form where all the grounds mentioned in section 271 are mentioned would not satisfy the requirement of law. The assessee should know the ground which he has to meet specifically, otherwise, the principle of natural justice is offended on the basis of such proceedings, no penalty could be imposed to the assessee. Ticking of the penalty proceedings on one limb and finding the assessee guilty of another limb is bad in law, therefore, we delete the penalty confirmed by the ld CIT(A). See CIT Vs M/s Manjunath Cotton & Ginning Factory & Ors [2013 (7) TMI 620 - KARNATAKA HIGH COURT] - Decided in favour of assessee
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