https://www.taxtmi.com/caselaws?id=767325 ITAT Mumbai quashed PCIT's revision order under section 263 directing AO to initiate penalty proceedings under section 270A for under-reporting of income. The tribunal held that PCIT cannot substitute his views where AO made no finding of concealment or inaccurate particulars. Following Chennai Metro Rail precedent, PCIT's intervention was erroneous as AO's decision not to initiate section 270A penalty proceedings was not prejudicial to revenue interest. Assessee's appeal was allowed. en-us Wed, 12 Mar 2025 00:00:00 +0530 Sat, 15 Mar 2025 08:41:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767325 ITAT Mumbai quashed PCIT's revision order under section 263 directing AO to initiate penalty proceedings under section 270A for under-reporting of income. The tribunal held that PCIT cannot substitute his views where AO made no finding of concealment or inaccurate particulars. Following Chennai Metro Rail precedent, PCIT's intervention was erroneous as AO's decision not to initiate section 270A penalty proceedings was not prejudicial to revenue interest. Assessee's appeal was allowed. Case-Laws Income Tax Wed, 12 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767325