General printed Notice imposing Penalty u/s 271(1)(C) is not sustainable

Brief of the case

In the case of Suvaprasanna Bhatacharya vs ACIT, ITAT Kolkata held that although the satisfaction need not be recorded in a particular manner but from a reading of the assessment order as a whole such satisfaction should be clearly discernible. It was further held that ‘concealment of income’ and ‘furnishing inaccurate particulars of income’ carry different connotations. Levy of penalty has to be clear as to the limb for which it is levied.

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