Purposive interpretation of residential house exemption: unregistered purchase agreement alone does not defeat relief, but investment must be verified...
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Section 263 revision requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. Where the Assessing Officer has called for and considered details on unsecured loans and trade payables, revision cannot rest merely on audit objections or an assumption that further inquiry would produce an addition under section 68. Explanation 2 creates a deeming framework for insufficient inquiry but does not remove the twin statutory requirements. In the stated circumstances, the assessment was made after inquiry, no revenue prejudice was identified, and the revisional order was quashed.
Section 263 revision requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. Where the Assessing Officer has called for and considered details on unsecured loans and trade payables, revision cannot rest merely on audit objections or an assumption that further inquiry would produce an addition under section 68. Explanation 2 creates a deeming framework for insufficient inquiry but does not remove the twin statutory requirements. In the stated circumstances, the assessment was made after inquiry, no revenue prejudice was identified, and the revisional order was quashed.
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