271(1)(C) is also initiated." 3.3. As per section
271 (1)(c) , the assessing officer is empowered to impose penalty ... under
section 271 (1)(c) is bad in law as it does not specify by
which limb of section 271 (1 )(c
penalty for concealment Under Section 271(1)(c).
(iii) Explanation 4 annexed to Section 271(1)(c), presupposes taxable income with regard to the assessment ... Section 271(1)(c) and has stated that the provisions of Section 143(1A) are similar to Section 271(1)(c) and thereafter came
1. On the facts and interest the circumstances, the Ld. CIT(A) has erred in
deleting the penalty imposed under section 271(1)(c) ignoring ... under s, 271(1)(c)--Concealment--Disallowance of claim for deduction
-- In order to attract the provisions of s, 271(1)(c), there
Submission of the assessee.
1. The ld. AO initiated the penalty proceeding u/s 271(1)(c) of Income
Tax Act in the assessment order ... Jaipur .
2. The notice U/s 271 should be specific on imposing of penalty u/s
271(1)(c) of Income
assessee.
1. Initiation of penalty in Assessment Order:-
The ld. AO initiated the penalty proceeding u/s 271(1)(c) of Income ... 271(1)(C) is also
initiated."
3.3. As per section 271 (1)(c) , the assessing officer is empowered to impose
penalty
notice u/s 271(1)(c) is bad in law
2. A perusal of the notice u/s 271(1)(c) clearly indicates
that ... Penalty under s. 271(1)(c) -Concealment-Disallowance of
claim for deduction-In order to attract the provisions ofs.
271(1)(c), there
income, the penalty proceedings initiated by the AO are illegal and invalid, and the penalty under Section 271(1)(c) imposed ... impose penalty under Section 271(1)(c) , has not recorded the mandatory satisfaction in terms of Section 271(1)(c) while finalising the assessment
under section
271(1)(c) of the Act. Accordingly, in view of the deeming provisions
of Explanation 5A to section 271(1)(c ... levied penalty under section 271(1)(c) of the Act only invoking the
Explanation 5A below section 271(1)(c
assessment years read as under:
"Order under Section 271(1)(c)
Penalty proceedings started in this case are hereby dropped ... Section 263(1) on 18th/22nd Jan., 1991, for the cancellation of the orders dropping the penalty proceedings under Section 271(1)(c
particulars
of income to warrant levy of penalty and therefore penalty levied u/s
271(1) ( c) of the Act, requires to be cancelled ... 271(1)(c) of
the Act. Explanation 5A to section 271(1)(c) of the Act has been invoked for
levying the said penalty
