https://www.taxtmi.com/caselaws?id=432824 The Tribunal held that the Principal Commissioner of Income Tax lacked jurisdiction under section 263 when the Assessing Officer did not initiate penalty proceedings under section 271(1)(c). It emphasized that without the Assessing Officer's findings on concealment of income or inaccurate particulars, the Principal Commissioner could not direct penalty proceedings through a revisionary order. The Tribunal quashed the Principal Commissioner's orders, stating that the Assessing Officer's failure to initiate penalty proceedings rendered the assessment order erroneous. The appeals for both assessment years were allowed, highlighting the importance of the Assessing Officer's role in such proceedings and the limitations on the Principal Commissioner's jurisdiction. en-us Thu, 29 Dec 2022 00:00:00 +0530 Sat, 14 Jan 2023 06:51:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432824 The Tribunal held that the Principal Commissioner of Income Tax lacked jurisdiction under section 263 when the Assessing Officer did not initiate penalty proceedings under section 271(1)(c). It emphasized that without the Assessing Officer's findings on concealment of income or inaccurate particulars, the Principal Commissioner could not direct penalty proceedings through a revisionary order. The Tribunal quashed the Principal Commissioner's orders, stating that the Assessing Officer's failure to initiate penalty proceedings rendered the assessment order erroneous. The appeals for both assessment years were allowed, highlighting the importance of the Assessing Officer's role in such proceedings and the limitations on the Principal Commissioner's jurisdiction. Case-Laws Income Tax Thu, 29 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432824