COMMISSIONER OF INCOME TAX (IT & TP) vs. M/S. DONGFANG ELECTRIC CORPORATION

Bench: : The Hon’Ble Justice Surya Prakash Kesarwani

reassessment shall be deemed to constitute satisfaction of the Assessing Officer for initiation of the penalty proceedings under the said clause (c)." By the aforesaid deeming provision a legal fiction is created. When the assessment order contains a direction for initiation of penalty proceedings such order shall deem to constitute satisfaction of the Assessing Officer for initiation of penalty proceedings