SHRI.S.J.SURYAH,CHENNAI, TAMIL NADU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(4), CHENNAI
In the result, appeal filed by the assessee is allowed and appeal filed by the Revenue is dismissed
ITA 806/CHNY/2023[2002-03]Status: DisposedITAT Chennai29 May 2024AY 2002-03
Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.806/Chny/2023 िनधा"रण वष"/Assessment Year: 2002-03 V. Shri S.J.Suryah, The Asst. Commissioner- No.35-1D, Of Income Tax, 114, Neelakanta Mehta Street, Central Circle-2(4), T. Nagar, Chennai-600 017. Chennai. [Pan: Alyps 3012 R] (अपीलाथ"/Appellant) (""यथ"/Respondent)
For Appellant: Shri B. Ramakrishnan, FCAFor Respondent: Shri P. Sajit Kumar, JCIT
Section 153ASection 271Section 271(1)(c)Section 274
d)….
he may direct that such person shall pay by way of penalty-
…….”
2. As can be seen from the use of language, the legislation has envisaged that..
i. Penalty proceeding u/s 271 has to be initiated only during the pendency of the proceeding and not on completion of the proceeding
ii. Before initiation, satisfaction on attraction of penal
