https://www.taxtmi.com/highlights?id=105221 Revision under section 263 cannot rest solely on an Assessing Officer's failure to record satisfaction or initiate penalty for alleged cash-transaction violations of section 269SS. It requires both an erroneous assessment order and prejudice to Revenue. Penalty under section 271D is independent of assessment proceedings and, under the applicable statutory scheme, falls within the Joint Commissioner's competence. The limitation governing that penalty cannot be bypassed by setting aside a completed assessment to create a fresh penalty foundation, particularly where the underlying transactions admit two plausible views. en-us Wed, 21 Oct 2026 08:37:56 +0530 Wed, 21 Oct 2026 08:37:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=105221 Revision under section 263 cannot rest solely on an Assessing Officer's failure to record satisfaction or initiate penalty for alleged cash-transaction violations of section 269SS. It requires both an erroneous assessment order and prejudice to Revenue. Penalty under section 271D is independent of assessment proceedings and, under the applicable statutory scheme, falls within the Joint Commissioner's competence. The limitation governing that penalty cannot be bypassed by setting aside a completed assessment to create a fresh penalty foundation, particularly where the underlying transactions admit two plausible views. Highlights Income Tax Wed, 21 Oct 2026 08:37:56 +0530 https://www.taxtmi.com/highlights?id=105221