Recording of satisfaction in assessment order about initiation of penalty is must

EFG Wealth Management (P) Ltd. Vs. DCIT (ITAT Mumbai)

As assessee had furnished all the details of its expenditure as well as income in its return; the same could not be viewed as furnishing of inaccurate particulars or concealment of income to attract the penalty under section 271(1)(c). It was up to the AO to accept its claim in the return or not. Further, recording of satisfaction in the assessment order about the initiation of penalty was must and in its absence, penalty was liable to be deleted.<

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