Section 271(1)(c) Penalty Initiation Requires Specific Satisfaction: Rajasthan HC

PCIT Vs Harish Jain (Rajasthan High Court) Rajasthan High Court has dismissed appeals filed by the Principal Commissioner of Income Tax (PCIT) against an order of the Income Tax Appellate Tribunal (ITAT), Jaipur. The High Court affirmed the Tribunal’s decision to quash a revisional order that had directed the Assessing Officer (AO) to initiate penalty proceedings under  of the Income Tax Act, 1961, against the assessee, Harish Jain. The core of the judgment revolves around the necessity for the AO to record specific satisfaction for the relevant penalty provision during assessment proce...