Penalty u/s 271(1)(c) not valid in absence of proper record of satisfaction

PCIT Vs Goa Coastal Resorts and Recreation Pvt. Ltd. (Bombay High Court)

Notice which is issued to the assessee must indicate whether the Assessing Officer is satisfied that the case of the assessee involves concealment of particulars of income or furnishing of inaccurate particulars of income or both, with clarity. If the notice is issued in the printed form, then, the necessary portions which are not applicable are required to be struck off, so as to indicate with clarity the nature of the satisfaction recorded.

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