https://www.taxtmi.com/caselaws?id=801395 Failure to record satisfaction for penalty for an alleged cash-transaction contravention does not, by itself, make an assessment erroneous and prejudicial to the Revenue. The penalty operates independently of income computation and, for the relevant year, fell within the Joint Commissioner's competence rather than the assessment process. Revision cannot create a fresh basis for, or bypass the separate limitation governing, penalty proceedings. Where the underlying cash transactions remain disputed and the restriction's applicability is uncertain amid divergent judicial views, non-initiation represents a plausible legal view. Revision jurisdiction therefore cannot be invoked to initiate or revive independent penalty proceedings. en-us Wed, 07 Oct 2026 00:00:00 +0530 Wed, 21 Oct 2026 08:37:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801395 Failure to record satisfaction for penalty for an alleged cash-transaction contravention does not, by itself, make an assessment erroneous and prejudicial to the Revenue. The penalty operates independently of income computation and, for the relevant year, fell within the Joint Commissioner's competence rather than the assessment process. Revision cannot create a fresh basis for, or bypass the separate limitation governing, penalty proceedings. Where the underlying cash transactions remain disputed and the restriction's applicability is uncertain amid divergent judicial views, non-initiation represents a plausible legal view. Revision jurisdiction therefore cannot be invoked to initiate or revive independent penalty proceedings. Case-Laws Income Tax Wed, 07 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801395