https://www.taxtmi.com/caselaws?id=790179 Revision under section 263 could not be sustained merely because the Assessing Officer initiated penalty proceedings under section 270A instead of section 271(1)(c). The Tribunal noted that section 263 requires a demonstrable error in the assessment order causing prejudice to Revenue, and the record showed that penalty proceedings had already been initiated; the dispute was only about the applicable penalty provision. That choice, by itself, did not render the assessment order erroneous and prejudicial. The revision order was therefore unsustainable, with reference also made to the hearing safeguard in section 275. en-us Mon, 06 Apr 2026 00:00:00 +0530 Mon, 20 Apr 2026 10:04:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790179 Revision under section 263 could not be sustained merely because the Assessing Officer initiated penalty proceedings under section 270A instead of section 271(1)(c). The Tribunal noted that section 263 requires a demonstrable error in the assessment order causing prejudice to Revenue, and the record showed that penalty proceedings had already been initiated; the dispute was only about the applicable penalty provision. That choice, by itself, did not render the assessment order erroneous and prejudicial. The revision order was therefore unsustainable, with reference also made to the hearing safeguard in section 275. Case-Laws Income Tax Mon, 06 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790179