https://www.taxtmi.com/caselaws?id=60859 The Tribunal upheld the CIT's order under section 263, finding that the Assessing Officer's failure to consider relevant judicial authorities and the Tribunal's decision before dropping penalty proceedings constituted a jurisdictional error prejudicial to revenue. The CIT's intervention was deemed necessary to rectify the erroneous dropping of penalty proceedings, requiring a fresh penalty order after affording the assessee a reasonable opportunity to be heard. The Tribunal emphasized the importance of considering all relevant contemporaneous documents with evidentiary value, even if not before the Assessing Officer initially, to ensure lawful jurisdiction under section 263. en-us Wed, 21 Aug 1991 00:00:00 +0530 Sat, 08 Jan 2011 13:26:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=60859 The Tribunal upheld the CIT's order under section 263, finding that the Assessing Officer's failure to consider relevant judicial authorities and the Tribunal's decision before dropping penalty proceedings constituted a jurisdictional error prejudicial to revenue. The CIT's intervention was deemed necessary to rectify the erroneous dropping of penalty proceedings, requiring a fresh penalty order after affording the assessee a reasonable opportunity to be heard. The Tribunal emphasized the importance of considering all relevant contemporaneous documents with evidentiary value, even if not before the Assessing Officer initially, to ensure lawful jurisdiction under section 263. Case-Laws Income Tax Wed, 21 Aug 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=60859