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TMI Blog2011 (4) TMI 363X X X X Extracts X X X X X X X X Extracts X X X X ..... on under explanation to Section 271(1B) of the Act added by the Finance Act, 2008 w.e.f.1.4.1989 -As per the judgment of Madras High Court in M. Sajjanraj Nahar v. CIT [ 2006 -TMI - 9613 - MADRAS High Court ] and judgment of this Court in CIT v. Pearey Lal and Sons (EP) Ltd.,the impugned order is set aside and the matter is remanded to the Tribunal for fresh decision in accordance with law - Appea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he case of M. Sajjanraj Nahar Vs. CIT (283 ITR 230), is correct when the Assessing Officer had recorded initiation of penalty proceedings u/s 271(1) (c) in the assessment order? 2. During the course of assessment, the Assessing Officer noticed that the assessee had unexplained income. While making addition on that account, it was directed that penalty proceedings be initiated under Section 271 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ording of satisfaction was a matter of substance and not mere of form and if satisfaction was reflected in the order, format of recording of satisfaction was not enough to invalidate the action. Reference was also made to statutory amendment clarifying this position under explanation to Section 271(1B) of the Act added by the Finance Act, 2008 w.e.f.1.4.1989. Reliance has also been placed on the j ..... X X X X Extracts X X X X X X X X Extracts X X X X
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