Revision under section 263 is not sustainable where the Assessing Officer has made specific inquiries, considered supporting material, and adopted a permissible view; a brief assessment order alone does not show lack of inquiry or permit substitution of the Commissioner's view. Administrative and finance expenses remained connected with the taxpayer's continuing business and retained loans, notwithstanding transfer of stock to an LLP. Capital loss on the sale of rented investment property and cost of improvement were supported by audited accounts, construction records and loan documents. Fixed-asset adjustments reflecting transfers between branches at book cost, without change in ownership or fresh capital expenditure, also did not justify revision. The revisionary order was quashed and the original assessment restored.
Revision under section 263 is not sustainable where the Assessing Officer has made specific inquiries, considered supporting material, and adopted a permissible view; a brief assessment order alone does not show lack of inquiry or permit substitution of the Commissioner's view. Administrative and finance expenses remained connected with the taxpayer's continuing business and retained loans, notwithstanding transfer of stock to an LLP. Capital loss on the sale of rented investment property and cost of improvement were supported by audited accounts, construction records and loan documents. Fixed-asset adjustments reflecting transfers between branches at book cost, without change in ownership or fresh capital expenditure, also did not justify revision. The revisionary order was quashed and the original assessment restored.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
