No Penalty U/s. 271(1)(c) if Not specifically mentioned in assessment order as to which limb penalty was imposed

ABR Auto (P) Ltd. Vs. ACIT (ITAT Delhi) After perusing the assessment order, we find that assessing officer also did not record his satisfaction for initiation of penalty proceedings, because while passing the assessment order dated 30-12-2011 passed under section 143(3)(ii) of the Act, the assessing officer has stated that “….. Penalty proceedings under section 271(1)(c) is being initiated separately for furnishing inaccurate particulars of income/concealment income……………….”, which is not sufficient and therefore, the penalty proceedings cannot be said to be validly initiated...