Taxsutra Alert - HC : Deletes concealment penalty absent specific direction in "assessment" order

Deletes Sec 271(1)(c) penalty on a dis-allowance, absent specific direction for penalty levy in assessment order; Among various disallowances, AO specifically recorded satisfaction about initiation of penalty proceedings relating to other issues considered appropriate by him; Specific omission of recording satisfaction on one issue not an inadvertent omission; Expression "issue penalty notice u/s 271(1)(c) as discussed above" mentioned in concluding part of assessment order material, as it refers to those heads where specific direction issued by AO; Interprets SC ruling in Mak Data Pvt. Ltd. : Allahabad HC

Triveni Engineering & Industries Ltd [[TS-322-HC-2014(ALL)]]