Revisionary jurisdiction fails where the Assessing Officer conducted enquiries and adopted a plausible view on deduction claims.

Revisionary jurisdiction under Section 263 cannot be invoked merely because the assessment order lacks detailed discussion where assessment records show that the Assessing Officer made specific enquiries, received complete responses and applied mind to the deductions claimed. The distinction between lack of enquiry and inadequate enquiry is material; a Principal Commissioner cannot revise an order merely to substitute a different view or direct fresh verification without identifying a specific error. As the Assessing Officer had adopted a plausible view consistent with decisions in the assessee's own cases, the requirements of an erroneous order and prejudice to Revenue were not met, rendering the revision invalid.

---

---

Issues: Whether revisionary jurisdiction under Section 263 could be invoked where the Assessing Officer had made enquiries into the deductions claimed and adopted a view already accepted in the assessee's own cases.

Analysis: The assessment records showed that specific queries were issued and complete responses were furnished on the claims relating to non-rural bad debts written off, employee share-option expenses and provision for bad and doubtful debts. The absence of elaborate discussion in the assessment order did not establish lack of enquiry where the record evidenced application of mind. The distinction between lack of enquiry and inadequate enquiry was material; revision cannot be founded merely on the latter or on a different view of the Principal Commissioner. The revisionary order also did not identify any specific error in the assessment order and instead directed fresh verification. The Assessing Officer's view was, in any event, a plausible view consistent with decisions in the assessee's own cases.

Conclusion: The twin conditions of an erroneous order and prejudice to Revenue were not satisfied; invocation of Section 263 was invalid and the revisionary orders were set aside.

---