The Tribunal held that the AO failed to apply his mind at the time of recording his satisfaction at the time of framing assessment to initiate the penalty proceedings under section 271(1)(c) and specify the limb, furnished inaccurate particulars of income or concealed particulars of income, under which penalty is initiated. Accordingly, initiation of the penalty proceeding was not sustainable in the eyes of law for want of valid satisfaction recorded by the Assessing Officer.(AY.2008-09, 2011-12)