Section 263 revision sustained where unsigned portal upload and omission of partner's profit share did not defeat revisional jurisdiction.

Revision under section 263 was sustained because the Principal Commissioner had examined the assessment record and formed a reasoned view that the order was erroneous and prejudicial to the Revenue; the fact that an unsigned copy was uploaded in the portal or that service was disputed did not defeat revisional jurisdiction where the physical file contained a duly signed assessment order. The revision was also upheld on merits because the Assessing Officer had omitted the assessee-partner's share of profit from tax in the assessment under section 143(3) read with section 153C, and the claimed exemption under section 10(2A) was not enough to displace the finding without proof that the amount had already been correctly assessed in the firm's hands. Fresh verification and reassessment were therefore justified.

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Issues: (i) Whether revision under section 263 of the Income-tax Act, 1961 was invalid because the assessment order uploaded in the portal was unsigned and allegedly not served; (ii) Whether the Principal Commissioner was justified in revising the assessment on the ground that the Assessing Officer omitted the assessee's share of profit.

Issue (i): Whether revision under section 263 of the Income-tax Act, 1961 was invalid because the assessment order uploaded in the portal was unsigned and allegedly not served.

Analysis: The jurisdiction under section 263 depends on whether the Principal Commissioner called for and examined the record and formed the view that the assessment order was erroneous in so far as it was prejudicial to the interests of the Revenue. The fact that an unsigned copy was uploaded in the portal, or that service was disputed, was held immaterial for the assumption of revisional jurisdiction where the physical record contained a duly signed assessment order and the assessment record was examined before revision.

Conclusion: The revision under section 263 was valid and the objection based on unsigned and unserved assessment order was rejected.

Issue (ii): Whether the Principal Commissioner was justified in revising the assessment on the ground that the Assessing Officer omitted the assessee's share of profit.

Analysis: The assessment record and the seized material indicated that the assessee, being a partner in the firm, had a share of profit that was not brought to tax in the assessment under section 143(3) read with section 153C. The assessee's reliance on exemption under section 10(2A) was found insufficient to dislodge the revisional finding because it was not established that the amount had already been assessed in the firm's hands or that the allocation had otherwise been correctly accounted for. The revisional authority was therefore justified in directing fresh verification and reassessment on this aspect.

Conclusion: The revision on merits was upheld and the omission to consider the share of profit was treated as making the assessment erroneous and prejudicial to the interests of the Revenue.

Final Conclusion: The assessment revision was sustained on both jurisdictional and substantive grounds, and the assessee's challenge failed in full.

Ratio Decidendi: For revision under section 263, the decisive requirement is examination of the assessment record and formation of a reasoned view that the order is erroneous and prejudicial to the interests of the Revenue; disputes about portal upload format or service do not by themselves invalidate the revisional power when the underlying signed assessment record exists and the substantive omission is established.

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