Initiation of penalty not valid if AO fails to record satisfaction for the same

Advocate Akhilesh Kumar Sah ACIT Vs M/s. International Cars & Motors Ltd (ITAT Delhi) Where no satisfaction had been recorded by the AO for initiation of penalty in the assessment order the same cannot invite the assessee to penalty under section 271(1)(c) Recently, in the, ACIT vs. International Cars & Motors Ltd [ITA Nos.5149 & 5150/Del/2016 AYs: 2007-08 & 2008-09, decided on 30.04.2019], the two appeals by the Revenue were directed against two separate orders dated 18/07/2016 passed by the Commissioner of Income-tax (Appeals)-4, New Delhi [in short ‘the CIT(A)’] in rela...