Penalty u/s 27(1)(c) - invocation of provisions of Section 263 - ...
Pr.CIT can't replace Assessing Officer's satisfaction when imposing penalties u/s 271(1) for assessment changes.
December 20, 2019
Case Laws Income Tax HC
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.
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