https://www.taxtmi.com/caselaws?id=27718 The High Court upheld the Commissioner's direction to the Income-tax Officer to consider charging interest under section 215, emphasizing that mere inaction cannot be considered waiver. The Court overruled a previous decision and affirmed the Commissioner's authority in this regard. However, the Court held that the Commissioner did not have the power to direct the initiation of penalty proceedings under section 263, as penalty proceedings are separate from assessment proceedings. The outcome favored the assessee over the Revenue in this regard. en-us Thu, 23 Feb 1984 00:00:00 +0530 Mon, 15 Feb 2010 15:51:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27718 The High Court upheld the Commissioner's direction to the Income-tax Officer to consider charging interest under section 215, emphasizing that mere inaction cannot be considered waiver. The Court overruled a previous decision and affirmed the Commissioner's authority in this regard. However, the Court held that the Commissioner did not have the power to direct the initiation of penalty proceedings under section 263, as penalty proceedings are separate from assessment proceedings. The outcome favored the assessee over the Revenue in this regard. Case-Laws Income Tax Thu, 23 Feb 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27718