Penalty u/s 271(1)(c) unsustainable in absence of recording of satisfaction

Pushpa Jadhav Vs ITO (ITAT Mumbai) ITAT Mumbai held that recording of satisfaction for initiating penalty u/s 271(1)(c) of the Act is not in accordance with the provisions of the Act, accordingly, penalty u/s 271(1)(c) not sustained. Facts- The assessee had not filed any return of income for the AY 2011-12 u/s 139 of the Income Tax Act, 1961. On realising the mistake, the assessee in March 2017 deposited the tax due for AY 2011-12 along with interest thereon. Thereafter, the assessee filed a letter dated 29.03.2017 before AO enclosing copy of the challan towards payment of tax and computation ...