Section 263 revision cannot stand without a clear lack of enquiry and resulting prejudice to revenue.

Revision under section 263 was held unsustainable because the assessment record showed that the Assessing Officer had issued notices, called for Chapter VIA details and examined the assessee's section 80G claim relating to CSR donations. In the absence of any specific omitted enquiry, or proof that the assessment order was erroneous due to non-application of law, the revisional precondition of both error and prejudice to revenue was not met. The Principal Commissioner could not invoke section 263 merely because he disagreed with the allowance of the deduction. The revisionary interference was therefore quashed and the assessment remained undisturbed.

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Issues: Whether the revisionary order under section 263 was sustainable where the Assessing Officer had called for details and allowed the assessee's claim of deduction under section 80G on CSR-related donations.

Analysis: The assessment record showed that notices under sections 143(2) and 142(1) were issued and details relating to the Chapter VIA claim were sought and furnished. The record did not establish any specific enquiry that was omitted by the Assessing Officer, nor did it demonstrate how the order was erroneous on the ground of non-application of law. In the absence of a clear failure of enquiry or verification, the conditions for invoking revision under section 263 were not satisfied. The conclusion was also supported by prior Tribunal decisions treating similar deductions as allowable and by the quashing of comparable revisionary orders.

Conclusion: The revision under section 263 was unsustainable and was quashed, in favour of the assessee.

Final Conclusion: The assessee's assessment was left undisturbed and the revisionary interference by the Principal Commissioner was set aside.

Ratio Decidendi: Section 263 cannot be invoked unless the revisional authority s both error in the assessment order and resultant prejudice to the revenue, and a mere disagreement with the Assessing Officer's allowance of a claim without demonstrating lack of enquiry is insufficient.

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