SATISFACTION

[vsaiyar]

In section 68, section 271 and Sec.14A etc. speaks of satisfaction of the Assessing Officer.  There are no standards or measures to determine when the AO could be said to be satisfied before invoking those provisions.  Can the satisfaction vary from Officer to Officer?  Since the AO is put in higher pedestal than the ordinary citizens an ordinary citizen cannot apply his own standards.  Can anyone suggest to me what are the prerequisites to decide whether there is satisfaction of the AO?

[vsaiyar]

one may keep in mind the followig decision.
Before initiating penal proceedings the assessing officer should be satisfied that there is a ground for levy of penalty.  In this context satisfaction means making up onae's own mind.  It is essentially a condition of mind, a mind not troubled by doubt, a mind that has reached a clear conclusion.  Such satisfaction should be derived in the course of any proceedings under the Act.  Jiten & Co., v/s STO 39 STC 308 (Delhi)

[mohiticai]

most of the AO's have one point agenda for satisfaction , which cannot be discussed on website. ;)