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2017 (2) TMI 219 - AT - Income TaxPenalty levied under section 271(1)(c) - non-recording of proper satisfaction by the Assessing Officer while completing assessment - Held that:- Assessing Officer while completing assessment and making disallowance on each account had stated that penalty under section 271(1)(c) of the Act needs to be initiated and the same was so initiated by issue of notice under section 274 r.w.s. 271(1)(c) of the Act. However, the Assessing Officer has failed to give satisfaction as to which limb of the said section has not been complied with by the assessee. In the absence of the same, proceedings initiated in the case by issue of notice in which inappropriate portion was not struck off are vitiated. Consequently, penalty order passed in the case is invalid and bad in law. Accordingly, we hold so. - Decided in favour of assessee.
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