CIT wrongly assumed jurisdiction u/s 263; AO didn't initiate penalty u/s 271(1)(c) or note satisfaction.

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....Revision u/s 263 - AO did not initiate penalty proceedings u/s. 271(1) (c) - No hesitation in holding that the CIT is not correct in assuming jurisdiction u/s 263 of the income tax act where the learned assessing officer has failed to initiate penalty proceedings and also does not record any satisfaction of furnishing of inaccurate particulars or concealment of income in the assessment order. - AT....