https://www.taxtmi.com/caselaws?id=25392 Jurisdiction of the Inspecting Assistant Commissioner to levy penalty under section 271(1)(c) turned on the date the Income-tax Officer made the reference, not the date when penalty proceedings were first initiated. The reference date was decisive because jurisdiction after deletion of section 274(2) survived only where the reference had been made before 1 April 1976 and remained pending on that date. On that test, the Tribunal was not justified in deciding jurisdiction by reference to initiation of proceedings, and the Revenue's position was accepted. en-us Mon, 10 Aug 1987 00:00:00 +0530 Thu, 28 Jan 2010 13:00:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=25392 Jurisdiction of the Inspecting Assistant Commissioner to levy penalty under section 271(1)(c) turned on the date the Income-tax Officer made the reference, not the date when penalty proceedings were first initiated. The reference date was decisive because jurisdiction after deletion of section 274(2) survived only where the reference had been made before 1 April 1976 and remained pending on that date. On that test, the Tribunal was not justified in deciding jurisdiction by reference to initiation of proceedings, and the Revenue's position was accepted. Case-Laws Income Tax Mon, 10 Aug 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=25392