https://www.taxtmi.com/caselaws?id=37723 The High Court upheld the validity of penalty proceedings initiated by the Income Tax Officer under Section 271(1)(a) of the Income Tax Act, 1961. It was determined that the penalty notice was issued during the assessment proceedings, ensuring the assessee had a reasonable opportunity to be heard as per Section 274. The Court clarified that the penalty imposition began within the same order as the assessment, even though physically issued later. The Tribunal's decision to overturn the cancellation of the penalty by the Appellate Assistant Commissioner was affirmed, and the case was remanded for further proceedings, with no costs awarded. en-us Tue, 06 Mar 1979 00:00:00 +0530 Wed, 31 Mar 2010 16:19:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37723 The High Court upheld the validity of penalty proceedings initiated by the Income Tax Officer under Section 271(1)(a) of the Income Tax Act, 1961. It was determined that the penalty notice was issued during the assessment proceedings, ensuring the assessee had a reasonable opportunity to be heard as per Section 274. The Court clarified that the penalty imposition began within the same order as the assessment, even though physically issued later. The Tribunal's decision to overturn the cancellation of the penalty by the Appellate Assistant Commissioner was affirmed, and the case was remanded for further proceedings, with no costs awarded. Case-Laws Income Tax Tue, 06 Mar 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37723