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2004 (9) TMI 45 - ALLAHABAD HIGH COURT
Jurisdiction of CIT to revise an order - Whether Tribunal was correct in holding that the assessment order passed by the Income-tax Officer without initiating penalty proceeding under section 273(c) for committing breach of section 212(3A) by the assessee, was not erroneous and prejudicial to the interests of the Revenue within the meaning of section 263 of the Income-tax Act, 1961? - If AO fails to initiate or record his satisfaction for the initiation of the penalty proceedings during the course of the assessment proceedings it would be a case where the assessment order can be said to be erroneous – Thus, we answer this question of in the negative, i.e., in favour of the Revenue and against the assessee.