https://www.taxtmi.com/caselaws?id=468381 Revisional jurisdiction under Section 263 cannot rest on an Assessing Officer's failure to initiate penalty proceedings where, at the relevant assessment date, the Assessing Officer lacked statutory authority to initiate or impose that penalty. It also cannot be used to substitute a Commissioner's preferred valuation methodology where the Assessing Officer considered the seized memorandum, subsequent registered sale, surrounding evidence, broker statement and valuation report, and adopted a plausible view after inquiry. Both error and prejudice to Revenue are required for revision. Writ jurisdiction remains available despite an alternative remedy where show-cause notices lack legal basis and conflict with the statutory framework. en-us Fri, 01 May 2026 00:00:00 +0530 Wed, 02 Sep 2026 10:21:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468381 Revisional jurisdiction under Section 263 cannot rest on an Assessing Officer's failure to initiate penalty proceedings where, at the relevant assessment date, the Assessing Officer lacked statutory authority to initiate or impose that penalty. It also cannot be used to substitute a Commissioner's preferred valuation methodology where the Assessing Officer considered the seized memorandum, subsequent registered sale, surrounding evidence, broker statement and valuation report, and adopted a plausible view after inquiry. Both error and prejudice to Revenue are required for revision. Writ jurisdiction remains available despite an alternative remedy where show-cause notices lack legal basis and conflict with the statutory framework. Case-Laws Income Tax Fri, 01 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468381