https://www.taxtmi.com/caselaws?id=66176 The Tribunal held that the Commissioner was not justified in invoking section 263 based on the non-initiation of penalty proceedings under section 271(1)(a) by the Income-tax Officer. The Tribunal emphasized that penalty proceedings are separate from assessment proceedings and must be initiated during the assessment. It was concluded that the Commissioner's order directing the initiation of penalty proceedings was not sustainable. Therefore, the appeal was allowed in favor of the assessee, and the Tribunal dismissed the Special Leave Petition against the decision. en-us Wed, 26 Aug 1987 00:00:00 +0530 Tue, 22 Feb 2011 10:05:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=66176 The Tribunal held that the Commissioner was not justified in invoking section 263 based on the non-initiation of penalty proceedings under section 271(1)(a) by the Income-tax Officer. The Tribunal emphasized that penalty proceedings are separate from assessment proceedings and must be initiated during the assessment. It was concluded that the Commissioner's order directing the initiation of penalty proceedings was not sustainable. Therefore, the appeal was allowed in favor of the assessee, and the Tribunal dismissed the Special Leave Petition against the decision. Case-Laws Income Tax Wed, 26 Aug 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=66176