Pr.CIT can't replace Assessing Officer's satisfaction when imposing penalties u/s 271(1) for assessment changes.

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....Penalty u/s 27(1)(c) - invocation of provisions of Section 263 - while the Pr.CIT could well initiate penalty u/s 271(1) if he proposed to effect modifications to the assessment itself, he cannot, in law substitute his satisfaction for that of the Assessing Officers’ for levying penalty in regard to the modifications to income effected in original assessment.....