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The Learned Counsel for the Assessee contended that A.O. has not recorded any satisfaction under section 271(1)(c) of the I.T. Act in assessment order for initiating the penalty proceedings.Learned Counsel for the Assessee, therefore, submitted that it is not clear from the assessment order as well as from the notice whether penalty have been initiated / levied for furnishing inaccurate particulars of income or concealment of particulars of income.

Shanti Prime Publication Pvt. Ltd.

Sec. 271(1) of Income Tax Act, 1961— Penalty— A.O. in the assessment order did not record any satisfaction as to for which limb of Section 271 (1)(c), the penalty proceedings have been initiated and merely mentioned at the bottom of the assessment order after computing the income that “penalty proceedings under section 271(1)(c) have been initiated separately, thus there is a violation of the Law in the matter, therefore, there was no justification to levy the penalty under section 271(1)(c) against the assessee - RAJ KUMAR V/s ITO - [2020] 82 ITR (TRIB) 509 (ITAT-DELHI)