Initiation of Penalty Proceeding U/s. 271(1)(c) in absence of clear finding is invalid

Pr CIT Vs. Baisetty Revathi (Andhra Pradesh High Court) In the present case, the assessee seems to have submitted her explanation on merits without raising a doubt as to what was the precise allegation leveled against her. However, we are more concerned with the principle involved and not just the isolated case of its application against the assessee. Further, the penalty order demonstrates that the Assessing Officer was not even certain as to what was the finding on the strength of which he imposed the penalty. This is clear from the fact that the Assessing Officer recorded that he was satisf...