ASSISTANT COMMISSIONER OF INCOME TAX, NON CORPORATE CIRCLE-10, CHENNAI vs. SJ SURYAH, CHENNAI
In the result, appeal filed by the assessee is allowed and appeal filed by the Revenue is dismissed
ITA 594/CHNY/2024[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
