https://www.taxtmi.com/caselaws?id=67829 Penalty proceedings under section 271(1)(c) are distinct from assessment proceedings, and their initiation during assessment is a matter of convenience rather than a legal requirement to be recorded in the assessment order. On that basis, an assessment order is not rendered erroneous or prejudicial to the interests of revenue merely because it does not initiate penalty proceedings in the order itself. Since the absence of such a recording does not by itself justify supervisory revision, action under section 263 is unwarranted. Where two interpretations are possible, the view more favourable to the assessee is preferred. en-us Thu, 19 Aug 1982 00:00:00 +0530 Mon, 14 Mar 2011 18:38:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=67829 Penalty proceedings under section 271(1)(c) are distinct from assessment proceedings, and their initiation during assessment is a matter of convenience rather than a legal requirement to be recorded in the assessment order. On that basis, an assessment order is not rendered erroneous or prejudicial to the interests of revenue merely because it does not initiate penalty proceedings in the order itself. Since the absence of such a recording does not by itself justify supervisory revision, action under section 263 is unwarranted. Where two interpretations are possible, the view more favourable to the assessee is preferred. Case-Laws Income Tax Thu, 19 Aug 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=67829