https://www.taxtmi.com/caselaws?id=12861 Non-initiation of penalty proceedings under section 271(1)(c) by itself did not make the assessment order erroneous or prejudicial to the interests of the Revenue for purposes of section 263. Where the addition to income had already attained finality, the Commissioner could not invoke revisionary jurisdiction merely to direct initiation of penalty proceedings. The Madras High Court held that such omission did not confer jurisdiction under section 263, and the reference was answered in favour of the assessee and against the Revenue. en-us Thu, 08 Nov 2001 00:00:00 +0530 Fri, 22 May 2009 15:52:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=12861 Non-initiation of penalty proceedings under section 271(1)(c) by itself did not make the assessment order erroneous or prejudicial to the interests of the Revenue for purposes of section 263. Where the addition to income had already attained finality, the Commissioner could not invoke revisionary jurisdiction merely to direct initiation of penalty proceedings. The Madras High Court held that such omission did not confer jurisdiction under section 263, and the reference was answered in favour of the assessee and against the Revenue. Case-Laws Income Tax Thu, 08 Nov 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=12861