The CIT(A) passed the order under section 154 as corrigendum. Held that CIT(A) no power to give direction to initiate penalty proceedings when no proceedings are pending before him. Direction to initiate penalty proceedings after culmination of appellate proceedings are without jurisdiction. (AY 2017-18)
Bhuramal Rajmal Surana & Sons (P) Ltd v. ACIT(2023) 225 TTJ 122 (SMC)(Jaipur)(Trib)
S. 251 : Appeal-Commissioner (Appeals)-Powers-Direction to initiate penalty proceedings-No proceedings were pending before CIT(A)-Direction to initiate penalty proceedings after culmination of appellate proceedings are without jurisdiction.[ S. 154, 250, 270A]