Sirs/Madam, My query is whether the CIT can initiate and levy concelament penalty u/s.271(1)(c) of the Incometax Act during the course of revisionary proceedings u/s.263 of the Act. Some say that the AO, CIT(Appeals) and CIT are empowered to levy such penalty u/s.271(1)(c). Whether AO is competent or CIT is equally empowered to levy such penalty during revisionary proceedings. Please clarify with supporting case laws. Thank u.
