Dismissing the appeal of the revenue the Court held that the Assessing Officer has not recorded satisfaction and even not-striking irrelevant portion in the notice, hence the deletion of penalty is held to be valid. Relied on CIT v. Shri Samson Perinchery (2017 392 ITR 4 (Bom) (HC) Pr. CIT v. New Era Sova Mine (2020) 420 ITR 376 (Bom) (HC)
PCIT v. Golden Peace Hotels and Resorts (P.) Ltd. (2021) 124 taxmann.com 248 (Bom.)(HC) Editorial : SLP of revenue dismissed, PCIT v. Golden Peace Hotels and Resorts (P.) Ltd. (2021) 277 Taxman 595 (SC))/ (2021) 437 ITR 9 (ST) (SC)
S. 271(1)(c) : Penalty-Concealment-Not recording satisfaction-Not striking irrelevant portion in the notice-Levy of penalty is not valid. [S. 260A]