No section 271(1)(b) Penalty Unless Conduct of Assessee Is Contumacious

Krishan Kumar Goel Vs DCIT (ITAT Delhi) AO has made additions and computed the income at Rs.1,88,85,961/-. Nowhere in the order of the AO there is any whisper that AO is not satisfied by the compliance by the assessee to his notices or queries. Now, the same AO has passed the above said penalty order. The above amply shows that there is lack of proper application of mind by the AO levying the penalty as well as the ld. CIT (A) upholding the same. The penalty order by the same AO is quite in contradiction to the assessment order passed by the same AO in which there is no whisper about lack of c...