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Section 271(1)(c) of the Income-tax Act, 1961 - Penalty - For concealment of income Where on a detailed perusal of assessment order no satisfaction of Assessing Officer that penalty proceedings were required to be initiated against assessee was discernible, imposition of penalty was not justified. [Assessment year 1984-85] (In the favour of assessee) CIT v M. K. Sharma [2008] 307 ITR 147 (Delhi) Where on a perusal of the assessment order, it was found that the Assessing Officer had in regard to initiation of penalty proceedings, observed as follows: 'Assessed. Issue necessary forms. Penalty under sections 271(1)(a), 271(1)( b), 271(1)(c) and 273/274 of the Income-tax Act have been initiated. Charge interest under sections 139(8) and 215/217 of the Income-tax Act'. Held that the above recording did not satisfy the requirement of section 271(1)(c) as explained by the instant court in CIT v. Ram Commercial Enterprises Ltd. [2000] 246 ITR 568. Further even on a detailed perusal of the assessment order, no satisfaction of the Assessing Officer that penalty proceedings were required to be initiated against the assessee was discernible. Ms. Prem Lata Bansal for the Appellant. JUDGMENT Despite service, no one appears for the respondent. 2. In this appeal under section 260A of the Income-tax Act, 1961 ("the Act"), the Revenue is aggrieved by an order dated January 27, 2006, passed by the Income-tax Appellate Tribunal ("the Tribunal"), Delhi Bench "B", New Delhi in I.T.A. No. 1450/Del/2004 for the assessment year 1984-85. By the impugned order, the Tribunal allowed the appeal filed by the asses-see challenging the levy of penalty under section 271(1)(c) of the Act. The penalty was set aside by the Tribunal on the ground that the Assessing Officer had not recorded any satisfaction in the assessment order that there was either concealment or inaccurate particulars furnished by the assessee. 3. Ms. Prem Lata Bansal, learned senior standing counsel for the Revenue, submits that in CIT v. Ram Commercial Enterprises Ltd.[2000] 246 ITR 568 this court has taken the view that if the Assessing Officer does not record his satisfaction in the assessment order that penalty…

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