https://www.taxtmi.com/caselaws?id=67803 Penalty under section 273(a) was treated as unsustainable because reassessment under sections 147 and 148 is distinct from a regular assessment under section 2(40), which is confined to assessments made under sections 143 or 144. The statutory satisfaction required for penalty proceedings under section 273 must arise in connection with a regular assessment, and that condition was not met when the proceedings were initiated and concluded in reassessment. The Revenue's challenge therefore failed, and the penalty could not be validly imposed on the basis of the reassessment proceedings. en-us Fri, 27 Mar 1981 00:00:00 +0530 Mon, 14 Mar 2011 16:49:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=67803 Penalty under section 273(a) was treated as unsustainable because reassessment under sections 147 and 148 is distinct from a regular assessment under section 2(40), which is confined to assessments made under sections 143 or 144. The statutory satisfaction required for penalty proceedings under section 273 must arise in connection with a regular assessment, and that condition was not met when the proceedings were initiated and concluded in reassessment. The Revenue's challenge therefore failed, and the penalty could not be validly imposed on the basis of the reassessment proceedings. Case-Laws Income Tax Fri, 27 Mar 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=67803