AO can initiate penalty proceeding only on issues on which he directs initiation of penalty proceeding in his Assessment Order

CA Sandeep Kanoi Section 271(1)(c) empowers inter alia the Assessing Officer, where he is satisfied in the course of any proceedings under the Act that the assessee had concealed the particulars of his income or furnished inaccurate particulars of such income, to direct the payment of penalty. Sub-section (1B) was introduced by way of an amendment by the Finance Act, 2008 with retrospective effect from 1 April 1989. Sub-section (1B) reads as follows:- “(1B)- Where any amount is added or disallowed in computing the total income or loss of an assessee in any order of assessment or reassessment...