https://www.taxtmi.com/caselaws?id=465986 The text addresses revision under revision jurisdiction and penalty for late tax audit filing, clarifying that additions made under fictional income provisions were treated as outside normal business income heads and thus beyond penalty invocation predicated on reassessment. It reasons that the revisional authority must confine itself to reasons recorded for reopening and cannot initiate penalty proceedings based on reassessment findings when additions arise from deemed or fictional income entries. It also states that statutory audit obligations do not extend to fictional income provisions, and accordingly the revisional order imposing penalty was set aside and the assessee's appeal allowed. en-us Thu, 06 Feb 2025 00:00:00 +0530 Sat, 17 Jan 2026 20:13:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465986 The text addresses revision under revision jurisdiction and penalty for late tax audit filing, clarifying that additions made under fictional income provisions were treated as outside normal business income heads and thus beyond penalty invocation predicated on reassessment. It reasons that the revisional authority must confine itself to reasons recorded for reopening and cannot initiate penalty proceedings based on reassessment findings when additions arise from deemed or fictional income entries. It also states that statutory audit obligations do not extend to fictional income provisions, and accordingly the revisional order imposing penalty was set aside and the assessee's appeal allowed. Case-Laws Income Tax Thu, 06 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465986