Dismissing the appeal of the revenue the Court held that Levy of penalty u/s 271(1)(c) is not valid if (i) there is no record of satisfaction by the AO that there was any concealment of income or that any inaccurate particulars were furnished by the assessee or (ii) If the notice is issued in the printed form and the inapplicable portions are not struck off.  Followed, CIT v.  Samson Perinchery (2017)  392 ITR 4 (Bom)(HC)  & PCIT v.  New Era Sova Mine (ITA Nos. 70 of 2018 dt 18-06 2019)

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[2019 SCC Online Bom 1032(Bom) (HC)].  Distinguished, Mak Data v. CIT (2013)  358 ITR 593 (SC) ( TA No.  24 of 2019, dt.  11. 11. 2019)