Set-Aside Assessment Cannot Trigger Penalty on Accepted Income

Ravinder Kumar Jain Vs DCIT (ITAT Delhi)

Set-Aside Assessment Not a Licence to Review Past Decisions: Penalty Deleted-AO Cannot Revive Penalty on Income Already Accepted in Original Assessment – Fresh Penalty in Remand Proceedings Held Invalid

In this appeal, Assessee challenged the penalty sustained by CIT(A) arising from penalty u/s 271(1)(c). Tribunal observed that the additional income of ₹58,85,666 was voluntarily offered in the original return & AO, while completing the original assessment on 28.12.2007, had not initiated any penalt

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