https://www.taxtmi.com/caselaws?id=311191 ITAT Hyderabad allowed the assessee's appeal and cancelled the PCIT's order under section 263. The PCIT had set aside the assessment order directing the AO to initiate penalty proceedings under section 271(1)(c). The tribunal held that once the PCIT records satisfaction for penalty imposition, the penalty proceedings must be completed by the PCIT alone and cannot be delegated to the AO. The PCIT's direction to the AO to record satisfaction and initiate penalty proceedings was deemed legally impermissible as it constituted an unauthorized delegation of authority. en-us Fri, 21 Jul 2023 00:00:00 +0530 Tue, 12 Dec 2023 20:02:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311191 ITAT Hyderabad allowed the assessee's appeal and cancelled the PCIT's order under section 263. The PCIT had set aside the assessment order directing the AO to initiate penalty proceedings under section 271(1)(c). The tribunal held that once the PCIT records satisfaction for penalty imposition, the penalty proceedings must be completed by the PCIT alone and cannot be delegated to the AO. The PCIT's direction to the AO to record satisfaction and initiate penalty proceedings was deemed legally impermissible as it constituted an unauthorized delegation of authority. Case-Laws Income Tax Fri, 21 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311191