PCIT cannot direct AO to initiate penalty proceedings u/s 271(1)(c)

Adithya Homes Private Limited Vs ACIT (ITAT Hyderabad) ITAT Hyderabad held that law doesn’t permit delegation of authority by PCIT to Assessing Officer (AO) for the purpose of imposition of penalty. Accordingly, direction issued by PCIT to AO to initiate penalty proceedings u/s 271(1)(c) of the Income Tax Act is unlawful. Facts- A search and seizure operation was conducted in the Red Rose Group. As part of the search operations, a warrant was issued in the case of assessee and search was conducted. Thereafter, notice u/s.153A was issued to the assessee. After verification of the information...