If CIT finds, while examining the records of an assessment order u/s 263, that AO has not initiated penalty proceedings, he cannot direct initiation of penalty proceedings because penalty proceedings are not a part of assessment proceedings - AT
If CIT finds, while examining the records of an assessment order u/s 263, that AO has not initiated penalty proceedings, he cannot direct initiation of penalty proceedings because penalty proceedings are not a part of assessment proceedings - AT
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