Dismissing the appeal of the revenue the Court held that there was no recording of satisfaction by Assessing Officer in relation to any concealment of income or furnishing of inaccurate particulars by assessee in notice issued for initiation of penalty proceedings under section 271(1)(c), same being sina qua non for initiation of such proceedings, Tribunal had rightly ordered to drop penalty proceedings. Distinguished. Mak Data (P.) Ltd. v. CIT (2013) 358 ITR 593 (SC)
PCIT v. Goa Coastal Resorts and Recreation (P.) Ltd. (2020) 272 Taxman 157 (Bom.)(HC) Editorial : SLP of revenue was dismissed , PCIT v. Goa Coastal Resorts and Recreation (P) Ltd ( 2021 ) 282 Taxman 463 ( SC)
S. 271(1)(c) : Penalty-Concealment-Not recording of satisfaction-Order of Tribunal quashing the reassessment proceeding was affirmed.