Penalty u/s 271(1)(c) Unsustainable if Assessment Order Validity is Questioned u/ss 153A and 153D.

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....Validity of penalty levied u/s 271(1)(c) where the validity of assessment order itself is in doubt - Assessment u/s 153A questioned on approval Granted u/s 153D - whether the assessment order can be challenged in the penalty proceedings? - The penalty levied by the AO in the penalty order framed under section 271(1)(c) of the Act is not sustainable. - AT....