https://www.taxtmi.com/caselaws?id=12989 The dominant issue was whether the CIT could invoke s.263 to revise the assessment on the ground that the AO failed to initiate penalty proceedings under s.271(1)(c) in respect of long-term capital gains on land acquisition compensation. The HC held that the dispute concerned only the correct year of taxability and the assessee had disclosed the transaction, believing capital gains were taxable on receipt; such circumstances did not constitute concealment or furnishing inaccurate particulars so as to attract s.271(1)(c). As no penalty was legally leviable for the relevant year, the CIT could not assume revisional jurisdiction under s.263 on that basis, and the Tribunal was right to set aside the s.263 order. en-us Wed, 26 Sep 2001 00:00:00 +0530 Tue, 06 Jan 2026 21:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=12989 The dominant issue was whether the CIT could invoke s.263 to revise the assessment on the ground that the AO failed to initiate penalty proceedings under s.271(1)(c) in respect of long-term capital gains on land acquisition compensation. The HC held that the dispute concerned only the correct year of taxability and the assessee had disclosed the transaction, believing capital gains were taxable on receipt; such circumstances did not constitute concealment or furnishing inaccurate particulars so as to attract s.271(1)(c). As no penalty was legally leviable for the relevant year, the CIT could not assume revisional jurisdiction under s.263 on that basis, and the Tribunal was right to set aside the s.263 order. Case-Laws Income Tax Wed, 26 Sep 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=12989