Section 263 revision requires lack of enquiry, not merely a different view when the Assessing Officer applied his mind.

Revisional jurisdiction under section 263 cannot be used merely because the revisional authority prefers a deeper or different enquiry where the Assessing Officer has already made enquiry, applied his mind and adopted a plausible view on the material. Here, the assessment records showed that cash deposits were specifically examined, the bank account details were called for, and the assessee's explanation that the deposits came from sale consideration of agricultural land was considered and accepted as satisfactory. As adequate enquiry had been made and a possible view taken, the revisional order setting aside the assessment for inadequate enquiry was unsustainable and was set aside; the assessment was restored.

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Issues: Whether the revisional order under section 263 of the Income-tax Act, 1961, setting aside the assessment on the ground of inadequate enquiry into cash deposits, was valid.

Analysis: The assessment records showed that the Assessing Officer had specifically called for an explanation regarding the cash deposits, obtained the bank account details, examined the assessee's explanation that the deposits arose from sale consideration of agricultural land, and recorded in the office note that the source stood explained satisfactorily. The authority under section 263 proceeded on a different view of the sale transaction and the evidentiary value of the agreement to sell, but the record demonstrated that enquiry had in fact been made and a plausible view had been taken. Once the Assessing Officer had applied his mind and adopted one of the possible views on the material before him, revisional interference could not be justified merely to direct a fuller or different enquiry.

Conclusion: The revisional order was unsustainable and was set aside; the assessment order was restored.

Ratio Decidendi: Section 263 cannot be invoked merely because the revisional authority prefers a deeper or different enquiry when the Assessing Officer has conducted an enquiry, applied his mind, and taken a plausible view on the material available.

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