Penalty procedure requires hearing, prior approval, and integration of penalty with assessment and reassessment orders.

Penalty proceedings require the assessee to be heard or given a reasonable opportunity of being heard, including by show cause notice. Prior approval of the Joint Commissioner is necessary before imposing a penalty above the prescribed thresholds, and any penalty order passed by an authority other than the Assessing Officer must be sent to the Assessing Officer. For later assessment or reassessment orders, penalty under section 439 is to be included in the assessment or reassessment order, and approval for such order is deemed to include approval for the penalty.

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