Revisionary jurisdiction requires an assessment order to be both...

Revisionary jurisdiction requires an assessment order to be both erroneous and prejudicial to Revenue interests. Tax was not required to be deducted on a back-to-back reimbursement of debenture interest paid through a fellow subsidiary because the intermediary did not receive income by way of interest; the revisionary authority neither disproved the supporting explanation nor established prejudice. Revision based on reconciled profit figures and ICDS adjustments was also unsustainable because the relevant details had been furnished and further verification was unnecessary. The revisionary order was quashed, the original assessment was restored, and the appeal was allowed.