https://www.taxtmi.com/caselaws?id=103127 The dominant issue was whether revision under s.263 could be sustained on the basis that the AO allegedly failed to examine low GP/NP and the genuineness of partners' capital introduced out of gifts. The Tribunal held that s.263 requires an order to be both erroneous and prejudicial to the interests of the Revenue, and the Commissioner must apply an objective standard; it is not a power for roving review. On the capital introduced, once the immediate source stood disclosed and the assessee-firm had discharged its onus under s.68, any further enquiry lay, if at all, in the partners' individual cases; the AO had applied his mind. The Commissioner's directions for fresh examination were set aside to that extent, and the appeal was partly allowed. en-us Mon, 30 Sep 2002 00:00:00 +0530 Thu, 08 Jan 2026 13:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=103127 The dominant issue was whether revision under s.263 could be sustained on the basis that the AO allegedly failed to examine low GP/NP and the genuineness of partners' capital introduced out of gifts. The Tribunal held that s.263 requires an order to be both erroneous and prejudicial to the interests of the Revenue, and the Commissioner must apply an objective standard; it is not a power for roving review. On the capital introduced, once the immediate source stood disclosed and the assessee-firm had discharged its onus under s.68, any further enquiry lay, if at all, in the partners' individual cases; the AO had applied his mind. The Commissioner's directions for fresh examination were set aside to that extent, and the appeal was partly allowed. Case-Laws Income Tax Mon, 30 Sep 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=103127