https://www.taxtmi.com/caselaws?id=789206 Section 264 revisional power is available against a penalty order even though an appeal also lies, unless the case falls within the express bars in sub-section (4); the assessee may choose between appeal under Section 246A and revision, so refusal to entertain revision solely for availability of appeal was unjustified. Penalty under Section 270A for under-reporting was also unsustainable because the same disallowance had already been reflected at the Section 143(1)(a) processing stage, the statutory ingredients of under-reporting were not met, and the claim was based on a debatable jurisdictional position with full disclosure and bona fide explanation. The penalty order was quashed. en-us Mon, 30 Mar 2026 00:00:00 +0530 Sat, 04 Apr 2026 08:53:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789206 Section 264 revisional power is available against a penalty order even though an appeal also lies, unless the case falls within the express bars in sub-section (4); the assessee may choose between appeal under Section 246A and revision, so refusal to entertain revision solely for availability of appeal was unjustified. Penalty under Section 270A for under-reporting was also unsustainable because the same disallowance had already been reflected at the Section 143(1)(a) processing stage, the statutory ingredients of under-reporting were not met, and the claim was based on a debatable jurisdictional position with full disclosure and bona fide explanation. The penalty order was quashed. Case-Laws Income Tax Mon, 30 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789206