Proportionality in company penalty quantification requires aggravating and mitigating factors; mechanical multiplication of director liability is impe...
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Revision u/s 263 - Since the assessment has already been set aside and the AO has been directed by the ld PCIT to re-frame it afresh after giving opportunity to the Assessee and after considering assessee’s explanation and all relevant material in accordance with law, therefore, we agree with the CIT and in our opinion, no interference is called for in the order of ld Pr. CIT. - AT
Revision u/s 263 - Since the assessment has already been set aside and the AO has been directed by the ld PCIT to re-frame it afresh after giving opportunity to the Assessee and after considering assessee’s explanation and all relevant material in accordance with law, therefore, we agree with the CIT and in our opinion, no interference is called for in the order of ld Pr. CIT. - AT
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