Penalty U/s. 271(1)(c) without finding of AO not justified

Whether Penalty Under Section 271(1)(c) Is Leviable Where There Is  Complete Absence Of The Recording Of Any Finding That The Assessee Had Indulged In Any Concealment Of Any Material Particulars Or That The Explanation Offered By Him Was Not Bonafide Or False

Recently, the Allahabad High Court in J.K. Synyhetics Ltd. vs. the CIT [ITA No. – 125 of 2002, decided on 19.12.2016] has deleted penalty under section 271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as the ‘Act’). In this appeal which related to A.Y. 1982-83, following questions of law were raised before Allahabad High Court:

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