Revisional jurisdiction under section 263 requires both error and revenue prejudice; mere disagreement with assessment is insufficient.

Section 263 revisional jurisdiction cannot be exercised unless the assessment order is both erroneous and prejudicial to the interests of the revenue. A mere difference of view or general dissatisfaction with the Assessing Officer's examination of cash credits and unsecured loans is insufficient, especially where the record shows enquiry into the relevant books and partners' capital contributions. Because the Commissioner did not record specific reasons demonstrating prejudice to revenue, the revisional order was set aside and the assessment order remained undisturbed.

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Issues: Whether the Commissioner could invoke revisional jurisdiction under section 263 to set aside the assessment order on the ground that the Assessing Officer had not properly examined the genuineness of the cash credits and unsecured loans.

Analysis: Revisional power under section 263 can be exercised only when the assessment order is both erroneous and prejudicial to the interests of the revenue. A mere difference of opinion between the Assessing Officer and the Commissioner is insufficient. The assessment record showed that the Assessing Officer had examined the relevant books and the partners' capital contributions, and the matter was not one of unexplained cash credit in the manner alleged. The Commissioner did not record specific reasons showing how the assessment order was prejudicial to the revenue so as to justify complete annulment and remand.

Conclusion: The order passed under section 263 was not justified and the assessee succeeded.

Final Conclusion: The appeal failed and the Tribunal's order setting aside the revisional order was sustained, leaving the assessment order undisturbed.

Ratio Decidendi: Section 263 cannot be invoked unless the assessment order is shown to be both erroneous and prejudicial to the interests of the revenue; a mere change of view or generalized dissatisfaction with the assessment is not enough.

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