https://www.taxtmi.com/caselaws?id=208669 Section 263 permits revision where an assessment order is both erroneous and prejudicial to the interests of the revenue, and an unexplained grant of foreign tax credit can satisfy that test. Because the assessment order did not disclose the basis for allowing treaty relief or show that the required computation had been undertaken, the Commissioner's direction to rework the entitlement was treated as a lawful exercise of revisional power rather than a mere change of opinion. The revisional order was upheld and the Tribunal's interference was held unsustainable. en-us Wed, 04 Jan 2012 00:00:00 +0530 Tue, 19 Aug 2025 11:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208669 Section 263 permits revision where an assessment order is both erroneous and prejudicial to the interests of the revenue, and an unexplained grant of foreign tax credit can satisfy that test. Because the assessment order did not disclose the basis for allowing treaty relief or show that the required computation had been undertaken, the Commissioner's direction to rework the entitlement was treated as a lawful exercise of revisional power rather than a mere change of opinion. The revisional order was upheld and the Tribunal's interference was held unsustainable. Case-Laws Income Tax Wed, 04 Jan 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208669