Penalty proceedings liable to be quashed for Inconsistency in recording of satisfaction and levy of penalty

Ashok Sahakari Sakhar Karkhana Ltd. Vs. Asst. CIT (ITAT Pune) A perusal of the satisfaction recorded for initiating penalty proceedings, the reasons for the levy of penalty mentioned in the notice and the reason given in the order levying penalty under section 271(1) (c) are not coherent. While recording reasons for initiating penalty proceedings and thereafter at the time of issuance of notice for levy of penalty vagueness and ambiguity in the mind of the assessing officer with respect to charge for the levy of penalty appears writ large. The assessing officer is not consistent in spec­ifyin...