Held that the original assessment and reassessment were two independent proceedings as were the penalty proceedings respectively initiated therein. Even if the reassessment order was quashed for any reason, the original assessment order would continue to exist. The AO imposed a penalty qua the income assessed in the original assessment for which a separate penalty notice was issued. The originally assessed income was further enhanced in the reassessment and therefore the additional income assessed in the reassessment would have separate penalty proceedings u/s.271 (1)(c), independent of the penalty qua the income assessed in the original assessment. That was the precise reason that the AO had initiated separate penalty proceedings in the order of reassessment. Matter remanded to CIT(A) on merits. (AY. 2012-13)