https://www.taxtmi.com/caselaws?id=119512 Section 263 revision requires a clear finding that the assessment order is both erroneous and prejudicial to the Revenue; a tentative view that matters were "apparently" not examined is insufficient. A revision order that merely directs further enquiry, without identifying a jurisdictional defect or legal error in the assessment, amounts to an impermissible fishing and roving exercise. On the facts, the assessee was entitled only to its share of surplus from the share premium suspense account, and the return disclosed United Kingdom tax residence with income offered under the treaty rate. In those circumstances, the assessment could not be treated as erroneous for lack of enquiry, and the revisionary invocation failed. en-us Wed, 11 Apr 2007 00:00:00 +0530 Wed, 11 Jul 2012 15:10:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=119512 Section 263 revision requires a clear finding that the assessment order is both erroneous and prejudicial to the Revenue; a tentative view that matters were "apparently" not examined is insufficient. A revision order that merely directs further enquiry, without identifying a jurisdictional defect or legal error in the assessment, amounts to an impermissible fishing and roving exercise. On the facts, the assessee was entitled only to its share of surplus from the share premium suspense account, and the return disclosed United Kingdom tax residence with income offered under the treaty rate. In those circumstances, the assessment could not be treated as erroneous for lack of enquiry, and the revisionary invocation failed. Case-Laws Income Tax Wed, 11 Apr 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=119512