PCIT not entitled to direct AO to initiate penalty proceedings

Dheeraj Singh Sisodiya Vs PCIT (ITAT Jaipur)

Held that revisional jurisdiction u/s. 263 of PCIT cannot be invoked for initiation of penalty proceedings without holding that the assessment order passed by the AO as erroneous and prejudicial to the interest of revenue.

Facts-

PCIT has erred on facts and in law in holding that in the order passed by AO he did not take a conscious decision relating to non­initiation/incorrect initiation of

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