Court :
HC
Brief :
Held by hon"ble court that a plain reading of section 271(1)(c) clearly shows that penalty proceedings under the said section cannot be initiated by the assessing officer without forming his opinion and recording his satisfaction.
Citation :
C.I.T Vs. Auto lamps Ltd.
Penalty for concealment of Income u/s 271(1)(c)
C.I.T Vs. Auto lamps Ltd. 5/5/2005
(2005) 278 ITR 32 (Delhi)
Case Fact: Whether it is necessary for the assessing officer to record his own satisfaction before starting proceedings under section 271(1)(c) .
Decision: Held by hon"ble court that a plain reading of section 271(1)(c) clearly shows that penalty proceedings under the said section cannot be initiated by the assessing officer without forming his opinion and recording his satisfaction.