https://www.taxtmi.com/caselaws?id=211391 HC held that the Commissioner's invocation of section 263 for AY 1982-83 was unjustified because his revisional order merely reiterated error without adequate reasons and without considering the assessee's explanations or evidence showing capital investments and unsecured loans were reflected in other assessments. The Court emphasized the quasi-judicial nature of s.263 requiring the Commissioner to examine explanations and call the assessee before altering an assessment. The revisional order was set aside and the reference answered in favour of the assessee and against the Revenue. en-us Mon, 16 Aug 2010 00:00:00 +0530 Wed, 15 Jul 2026 14:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=211391 HC held that the Commissioner's invocation of section 263 for AY 1982-83 was unjustified because his revisional order merely reiterated error without adequate reasons and without considering the assessee's explanations or evidence showing capital investments and unsecured loans were reflected in other assessments. The Court emphasized the quasi-judicial nature of s.263 requiring the Commissioner to examine explanations and call the assessee before altering an assessment. The revisional order was set aside and the reference answered in favour of the assessee and against the Revenue. Case-Laws Income Tax Mon, 16 Aug 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=211391