https://www.taxtmi.com/caselaws?id=470272 Revision under Section 263 was considered unsustainable where a bank credit was certified as enhanced compensation transmitted by the High Court following compulsory acquisition of agricultural land. As the source and manner of receipt were explained, an addition made as unexplained cash credits could not be subjected to the higher tax rate for unexplained income under Section 115BBE. A pending appellate challenge to the quantum addition did not change that position. Further, initiation of penalty under Section 271AAC lies within the Assessing Officer's discretion, and non-initiation did not make the assessment erroneous and prejudicial to Revenue. The revisionary order was quashed. en-us Wed, 19 Mar 2025 00:00:00 +0530 Tue, 21 Jul 2026 19:10:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470272 Revision under Section 263 was considered unsustainable where a bank credit was certified as enhanced compensation transmitted by the High Court following compulsory acquisition of agricultural land. As the source and manner of receipt were explained, an addition made as unexplained cash credits could not be subjected to the higher tax rate for unexplained income under Section 115BBE. A pending appellate challenge to the quantum addition did not change that position. Further, initiation of penalty under Section 271AAC lies within the Assessing Officer's discretion, and non-initiation did not make the assessment erroneous and prejudicial to Revenue. The revisionary order was quashed. Case-Laws Income Tax Wed, 19 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470272