PCIT Oversteps Powers by Ordering Penalty Without Assessment Finding

Atma Ram Builders Private Limited Vs ITO (ITAT Delhi) PCIT Cannot Direct Penalty Initiation under Section 271E: ITAT Quashes 263 Order for Want of AO’s Satisfaction The Delhi ITAT allowed the assessee’s appeal and set aside the revision order passed under Section 263, holding that the PCIT had no jurisdiction to direct initiation of penalty proceedings under Section 271E in the absence of satisfaction recorded by the Assessing Officer in the assessment order. The case arose from an alleged violation of Section 269T based on the tax audit report showing repayment of ₹11 lakh otherwise tha...