Penalty cannot be imposed U/s. 271(1)(c) in absence of recording of satisfaction by AO

Indrani Sunil Pillai Vs. ACIT (ITAT Mumbai) A reading of the impugned assessment order makes it clear that the Assessing Officer has initiated penalty proceedings under section 271(1)(c) without recording any satisfaction as to whether the assessee has furnished inaccurate particulars of income or concealed particulars of income. He has simply mentioned “the penalty proceedings u/s 271(1)(c) are initiated”. There is not even an allegation by the Assessing Officer anywhere in the assessment order that the assessee has either concealed the particulars of income or furnish inaccurate particul...