Section 271AAD penalty initiation cannot be directed through revisionary jurisdiction before false entries receive final determination.

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....Section 271AAD authorises only the Assessing Officer, Joint Commissioner (Appeals) and Commissioner (Appeals) to initiate or impose penalty for false entries in books of account; it does not confer that power on the Principal Commissioner or Commissioner. Penalty is not automatic and requires a final determination that a false entry exists. Revisionary jurisdiction cannot be used to direct the Assessing Officer to commence section 271AAD penalty proceedings while the underlying disallowance of contract expenditure remains under appellate consideration. The revisionary direction was therefore legally unsustainable and was quashed.....