Penalty Notice Challenge Only Valid Post-Order, Current Appeal Dismissed as Premature Under Legal Procedure.

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....Validity of notice proposing levy of penalty - mere initiation of penalty proceedings cannot be challenged unless some formal order on the point has been passed in accordance with law. The assessee may challenge the imposition of penalty if so legally advised at appropriate stage. The present appeal is infructuous in effect and substance and thus dismissed in limine. - AT....