ITO cannot initiate proceedings under Section 263

CIT Vs Shri Jheendu Ram (Allahabad High Court) In the instant case, the Tribunal has found that it is only the satisfaction of the Principal Commissioner/Commissioner of Income Tax himself that too after applying his mind and after examining the record of any proceeding. It is required to record his satisfaction the proceedings under Section 263 can validly be initiated. But in the instant case in the order of the Commissioner of Income Tax, it is noticed that nowhere the Commissioner of Income Tax has recorded his satisfaction, rather the satisfaction was of the Income Tax Officer (Technical)...