Proceedings u/s 263(1) could only be invoked after satisfaction of its Ingredients

Brief of the Case

In the present case the Hon’ble Tribunal held that for invoking section 263 both the conditions that the order of AO is erroneous as well prejudicial to the interest of Revenue should be satisfied

Facts of the Case

In this case CIT has issued show cause notice u/s 263 on the basis that AO has dropped the penalty proceedings initiated u/s 271(1)(c) on the ground that it is a voluntary surre

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