https://www.taxtmi.com/caselaws?id=796949 Revisionary jurisdiction cannot be invoked solely because the Assessing Officer did not initiate penalty proceedings for under-reporting or misreporting of income while completing reassessment. Penalty proceedings are independent of assessment proceedings, so omission to record or initiate penalty action does not make the assessment order erroneous and prejudicial to the Revenue. A contrary coordinate-bench view was distinguishable because it had not considered the binding High Court authority applied here. Revision founded only on non-initiation of penalty proceedings was therefore invalid. en-us Wed, 05 Aug 2026 00:00:00 +0530 Thu, 13 Aug 2026 08:30:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796949 Revisionary jurisdiction cannot be invoked solely because the Assessing Officer did not initiate penalty proceedings for under-reporting or misreporting of income while completing reassessment. Penalty proceedings are independent of assessment proceedings, so omission to record or initiate penalty action does not make the assessment order erroneous and prejudicial to the Revenue. A contrary coordinate-bench view was distinguishable because it had not considered the binding High Court authority applied here. Revision founded only on non-initiation of penalty proceedings was therefore invalid. Case-Laws Income Tax Wed, 05 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796949