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Sec. 271 of Income Tax Act, 1961—Penalty— The penalty proceedings being a separate proceeding, if at all, the AO intends to levy penalty, then the AO is bound to record the satisfaction that the explanation offered by the assessee is false and in the case of assessee, since the AO has not recorded such findings, penalty levied is un-sustainable and hence it is deleted - GURUSAMY RAMAMURTHY V/s ITO - [2020] 81 ITR (TRIB) 009 (ITAT-CHENNAI)