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2021 (6) TMI 249 - AT - Income TaxPenalty u/s 271(1)(c) - whether the assessee has concealed particulars of income or has furnished inaccurate particulars of income during assessment proceedings? - non recording of satisfaction by AO - HELD THAT:- When the AO has failed to apply his mind while recording satisfaction at the time of framing assessment to initiate the penalty proceedings u/s 271(1)(c) of the Act as to under which limb of section 271(1)(c) of the Act i.e. for concealing of particulars of income or furnishing of inaccurate particulars of income, such penalty proceedings initiated on the basis of vague and ambiguous satisfaction are not sustainable in the eyes of law. Consequently, ld. CIT(A) has rightly deleted the penalty levied by the AO. Finding no illegality or perversity in the impugned order, appeal filed by the Revenue is hereby dismissed.
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