CIT Cannot Overrule AO's Decision Not to Levy Penalty u/s 271AAA; Revision u/s 263 Challenged.

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....Non-levy of Penalty u/s 271AAA - revision u/s 263 - AO being quasi judicial authority has not initiated the penalty proceedings in the assessment order is his jurisdictional authority. The ld. CIT cannot just substitute the authority of the AO with his opinion. - AT....