Initiation of penalty u/s 271(1)(c) pre-requisite recording of satisfaction by AO; SLP dismissed

INCOME TAX : SLP dismissed against High Court ruling that recording of satisfaction by Assessing Officer that there was concealment of income or that any inaccurate particulars were furnished by assessee was sine qua non for initiation of penalty proceedings and in absence of such satisfaction, both Commissioner (Appeals) as well as Tribunal had correctly ordered to drop penalty proceedings against assessee

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