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Revisionary power under section 263 was examined in relation to a disallowance under section 11 for payments to specified/related persons; ITAT held the revisional authority failed to conduct its own enquiry and improperly remanded the matter for fresh verification, which constitutes an impermissible roving inquiry. The Assessing Officer had sought and considered detailed explanations and documents from the assessee before passing the assessment, and no material demonstrated falsity or discrepancy. Because no prejudice to revenue arose (taxes paid by specified persons and no taxable income in trust), the CIT(E)'s revision was set aside and the assessee's grounds allowed.
Revisionary power under section 263 was examined in relation to a disallowance under section 11 for payments to specified/related persons; ITAT held the revisional authority failed to conduct its own enquiry and improperly remanded the matter for fresh verification, which constitutes an impermissible roving inquiry. The Assessing Officer had sought and considered detailed explanations and documents from the assessee before passing the assessment, and no material demonstrated falsity or discrepancy. Because no prejudice to revenue arose (taxes paid by specified persons and no taxable income in trust), the CIT(E)'s revision was set aside and the assessee's grounds allowed.
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