https://www.taxtmi.com/caselaws?id=757316 ITAT Chennai held that PCIT's revision order u/s 263 directing AO to initiate penalty proceedings u/s 271(1)(c) was invalid. The assessment was framed u/s 153C but AO incorrectly initiated penalty u/s 271AAC (non-existent provision). Since the assessment order contained no finding of income concealment or inaccurate particulars, PCIT lacked jurisdiction to direct penalty initiation through revisionary powers. The tribunal distinguished between penalty levy powers during ongoing proceedings and revisionary powers u/s 263, ruling the latter cannot direct penalty initiation without recorded satisfaction of concealment. Appeal allowed. en-us Wed, 14 Aug 2024 00:00:00 +0530 Wed, 21 Aug 2024 17:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757316 ITAT Chennai held that PCIT's revision order u/s 263 directing AO to initiate penalty proceedings u/s 271(1)(c) was invalid. The assessment was framed u/s 153C but AO incorrectly initiated penalty u/s 271AAC (non-existent provision). Since the assessment order contained no finding of income concealment or inaccurate particulars, PCIT lacked jurisdiction to direct penalty initiation through revisionary powers. The tribunal distinguished between penalty levy powers during ongoing proceedings and revisionary powers u/s 263, ruling the latter cannot direct penalty initiation without recorded satisfaction of concealment. Appeal allowed. Case-Laws Income Tax Wed, 14 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757316