Invocation of Section 263 to initiate Penalty proceeding not sustainable when addition itself deleted by ITAT

Agencies Rajasthan Pvt. Ltd. Vs PCIT (ITAT Jaipur) Invocation of Section 263 of Income Tax Act, 1961 to initiate Penalty proceeding not sustainable when addition itself deleted by ITAT Brief facts of the case are that assessment u/s 143(3) of the Act was completed on 30-12-2017 by the AO and thus the AO made the addition / disallowance under different heads. Later on, the ld. Pr.CIT considered that the AO had failed to initiate the penalty proceedings u/s 271(1)(c) of the Act despite recording of clear cut findings about the bogus nature of the short term capital loss claimed by the assessee. ...