Penalty not leviable if vagueness & ambiguity in recording of satisfaction

Chandu Laxman Chavan Vs DCIT (ITAT Pune)

While levying penalty, the Assessing Officer invoked only the charge of “furnishing inaccurate particulars of income”. It is evident that while recording satisfaction the Assessing Officer was not clear in his mind as to which charge u/s. 271(1) (c) is to be invoked for initiating penalty. The ambiguity in the mind of Assessing Officer with regard to charge u/s. 271(1)(c) for levy of penalty is evident writ large.

7. Ginning Factory reported as 359 ITR 565 has held the “assessee should know th

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