Section 270A(8) of the Income Tax Act

Revisional powers under Section 263 can be exercised even if the issue is debatable, provided the order is erroneous and prejudicial to the revenue's interest.

Where civil or evil consequences ensue from the action of a statutory authority, the principles of natural justice must be followed, even if not explicitly stated in the statute. Failure to comply with these principles may render a statute ultra vires Article 14 of the Constitution.

The Commissioner can invoke revisional jurisdiction under Section 263 even when the assessee has disclosed all facts, if the Assessing Officer failed to examine those details in accordance with the correct provisions of law. Full disclosure does not provide immunity from revision if the assessment order is erroneous and prejudicial to the revenue due to the AO's inadequate inquiry.

When initiating penalty proceedings, the Assessing Officer (AO) must specify the limb of the charge, indicating whether the penalty is for concealment of income or furnishing inaccurate particulars. This requirement is essential for valid penalty proceedings.

Penalty under Section 270A of the Income Tax Act, 1961, cannot be imposed if the Assessing Officer fails to specify which clause under Section 270A(9) applies and fails to show cause to the assessee accordingly. Strict adherence to the conditions of Section 270A is mandatory for its applicability.

An assessment order is erroneous and prejudicial to the revenue's interest if it is passed without proper verification or application of mind by the Assessing Officer. Revisionary powers under section 263 can be invoked even if only one item in the assessment order is prejudicial.

If agricultural operations are being carried out on land at the time of sale and revenue records indicate it is agricultural land, a presumption arises that it is agricultural in character, which the revenue must rebut. Permission to convert land to non-agricultural use does not render it non-agricultural if not obtained before the sale.

The Assessing Officer's satisfaction for imposing a penalty under Section 271(1)(c) must be discernible from the assessment order, even if not expressly recorded in a specific format.

The potential non-agricultural value of land, or the large price a purchaser is willing to pay due to market conditions, does not change its essential character as agricultural land at the time of sale, provided it was used for agricultural purposes.