https://www.taxtmi.com/caselaws?id=463634 HC held that revision under section 263 was valid where the AO's order dropping penalty proceedings prejudiced revenue. Section 263's phrase "any order" was given broad scope to include initiation or dropping of proceedings. The HC found the assessment order did record satisfaction to initiate penalty under section 271(1)(c), so the Commissioner's revision to reinstate penalty proceedings was upheld. The Tribunal's contrary interference was unsustainable; the question of law was answered for the revenue. The matter is remanded to the Tribunal for factual adjudication on penalty quantum. en-us Tue, 27 Feb 2024 00:00:00 +0530 Tue, 09 Sep 2025 19:02:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463634 HC held that revision under section 263 was valid where the AO's order dropping penalty proceedings prejudiced revenue. Section 263's phrase "any order" was given broad scope to include initiation or dropping of proceedings. The HC found the assessment order did record satisfaction to initiate penalty under section 271(1)(c), so the Commissioner's revision to reinstate penalty proceedings was upheld. The Tribunal's contrary interference was unsustainable; the question of law was answered for the revenue. The matter is remanded to the Tribunal for factual adjudication on penalty quantum. Case-Laws Income Tax Tue, 27 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463634