Exercise of revisional power under section 263 is limited to...

Exercise of revisional power under section 263 is limited to orders that are not merely erroneous but prejudicial to revenue; a mere difference of opinion between the Assessing Officer and the Commissioner cannot justify setting aside, modifying or remanding an assessment, and the Commissioner must record reasons specifying how and to what extent the assessment is prejudicial. On addition of alleged cash credits under section 68, the AO had examined partners' accounts and sources and recorded satisfaction as to genuineness; that factual satisfaction was not shown to be prejudicial, so interference was unwarranted and the appeal was dismissed.

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