CIT (A) cannot initiate & levy penalty u/s 271(1) (c) by penalty order under his adjudication

Brief of the Case

ITAT Pune held In the case of Shri Ajit Ramchandra Jadhav. vs. ACIT that the order initiating the penalty proceedings has to be a different order and has to be passed by the person, who has made the addition / assessment in the hands of the assessee. In case the said person is CIT (A), then he is competent to initiate the penalty proceedings and also competent to levy the penalty by passing a separate order, but the CIT (A) is not competent to initiate and levy the penalty for c

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