https://www.taxtmi.com/caselaws?id=778355 ITAT AHMEDABAD allowed the appeal, holding that a revisional order under s.263 cannot direct initiation of penalty proceedings under s.270A because assessment and penalty proceedings are distinct. The tribunal followed HC authority that absence of a penalty reference in the assessment order does not make the assessment erroneous; initiation of penalty may be recorded separately and penalty proceedings can be started before assessment completion though the penalty order awaits final assessment. As no higher contrary precedent was cited, the direction in the s.263 order to initiate penalty proceedings was held beyond jurisdiction and set aside. en-us Mon, 08 Sep 2025 00:00:00 +0530 Mon, 15 Sep 2025 08:26:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778355 ITAT AHMEDABAD allowed the appeal, holding that a revisional order under s.263 cannot direct initiation of penalty proceedings under s.270A because assessment and penalty proceedings are distinct. The tribunal followed HC authority that absence of a penalty reference in the assessment order does not make the assessment erroneous; initiation of penalty may be recorded separately and penalty proceedings can be started before assessment completion though the penalty order awaits final assessment. As no higher contrary precedent was cited, the direction in the s.263 order to initiate penalty proceedings was held beyond jurisdiction and set aside. Case-Laws Income Tax Mon, 08 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778355