Revision u/s 263 - AO did not initiate penalty proceedings u/s. ...

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

January 14, 2023

Case Laws Income Tax AT

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

View Source

← Previous Next →

Revision u/s 263 - AO did not initiate penalty proceedings u/s. ...

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

January 14, 2023

Case Laws Income Tax AT

You may also like:

Penalty u/s 271(1)(c) - Disallowance u/s 40(a)(ia) - AO has not applied his mind before initiating the penalty proceedings rather borrowed his satisfaction from the “tax...

The Assessing Officer (AO) consciously deleted irrelevant portions from the show cause notice, mentioning only the charge of furnishing inaccurate particulars of income....

Revision u/sec. 263 - CIT has exceeded his jurisdiction in directing the Assessing Officer to initiate penalty proceedings u/s 271(1)(c) - AT

Penalty u/s 271(1)(c) - non recording of satisfaction - When satisfaction for initiation of penalty proceedings u/s 271(1)(c) of IT Act is recorded by the AO in...

The case involved a dispute over penalty imposition u/ss 271(1)(c) versus 271(1B) for additions related to estimated income from share trading transactions. The...

Penalty u/s 271(1)(c) - Mandation of specification of charge - It is clear that for the AO to assume jurisdiction u/s 271(1)(c), proper notice is necessary and the...

Voluntary surrender of income by assessee cannot be considered concealment. AO failed to prove concealment, merely concluded voluntary surrender as concealment....

Revision u/s 263 - Penalty u/s 271(1)(c) dropped - voluntarily offer certain income in the form of cash deposits/FDRs - a perusal of the ‘order sheet’ noting of the A.O...

Assessment u/s 153A - Need for spelling out ‘Satisfaction note’ - the ld. CIT(A) while adjudicating the legal issue of the validity of the satisfaction note prepared by...

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...

The assessment order passed u/s 153C was erroneous and prejudicial to the Revenue's interest. The Assessing Officer initiated penalty proceedings u/s 271AAC instead of...

Revision u/s 263 by CIT - mistake of non-initiation or incorrect initiation of penalty - the inherent indication u/s 271(1) makes it clear that the Pr. CIT / CIT does...

Penalty imposed u/s 271(1)(c) - satisfaction relates to Section 271AAA - satisfaction of the AO qua a wrong section for the purposes of penalty of strict nature is...

Penalty u/s 271(1)(c) - recording of satisfaction - penalty initiated u/s 143(3) order for concealment of particulars of income - penalty imposed for furnishing of...

Penalty u/s 271 AAB or u/s 271 (1)(c) - concealment on income - as per clause (2) of section 271AAB, no penalty under the provisions of clause (c) of sub-section (1) of...

Quick Updates: