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The ITAT reviewed a tax assessment case involving procedural penalty provisions. The Assessing Officer (AO) correctly applied Section 271AAC(1) in the reassessment order but erroneously issued a penalty notice under Section 271(1)(c). The tribunal held that the revisionary jurisdiction exercised by directing the AO to issue the correct penalty notice was legally valid. The tribunal found no procedural irregularity warranting interference and consequently dismissed the assessee's appeal, upholding the original order's substantive legal intent while mandating technical correction of the penalty notice.
The ITAT reviewed a tax assessment case involving procedural penalty provisions. The Assessing Officer (AO) correctly applied Section 271AAC(1) in the reassessment order but erroneously issued a penalty notice under Section 271(1)(c). The tribunal held that the revisionary jurisdiction exercised by directing the AO to issue the correct penalty notice was legally valid. The tribunal found no procedural irregularity warranting interference and consequently dismissed the assessee's appeal, upholding the original order's substantive legal intent while mandating technical correction of the penalty notice.
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