https://www.taxtmi.com/caselaws?id=8294 Penalty under section 28(1)(c) can be imposed only by the authority before which concealment or inaccurate particulars are found in the course of proceedings pending before that authority. Where additional income is discovered only in appellate proceedings before the Appellate Assistant Commissioner, the Income-tax Officer lacks jurisdiction to levy penalty for that amount, and the penalty is valid only in relation to the proceedings before the competent authority. A composite penalty order cannot be split into lawful and unlawful parts where no separate attribution is possible. Accordingly, an inseverable composite penalty covering both categories of income is invalid in its entirety. en-us Mon, 22 Feb 1971 00:00:00 +0530 Thu, 09 Apr 2009 11:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8294 Penalty under section 28(1)(c) can be imposed only by the authority before which concealment or inaccurate particulars are found in the course of proceedings pending before that authority. Where additional income is discovered only in appellate proceedings before the Appellate Assistant Commissioner, the Income-tax Officer lacks jurisdiction to levy penalty for that amount, and the penalty is valid only in relation to the proceedings before the competent authority. A composite penalty order cannot be split into lawful and unlawful parts where no separate attribution is possible. Accordingly, an inseverable composite penalty covering both categories of income is invalid in its entirety. Case-Laws Income Tax Mon, 22 Feb 1971 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8294