https://www.taxtmi.com/caselaws?id=333947 Section 263 revision is not justified where the Assessing Officer has made enquiries on the unsecured loan and cash deposit issue, examined supporting records, and accepted one permissible view of the evidence. The Commissioner cannot substitute a different opinion or rely on an audit objection and a reappraisal of the same material unless there is a clear, reasoned finding that the assessment order is both erroneous and prejudicial to the interests of revenue. Mere desire for further enquiry, or an allegation of inadequate enquiry without demonstrating error in the assessment, does not confer revisionary jurisdiction. The original assessment was therefore not capable of revision on the facts found. en-us Thu, 06 Oct 2016 00:00:00 +0530 Fri, 28 Oct 2016 14:12:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=333947 Section 263 revision is not justified where the Assessing Officer has made enquiries on the unsecured loan and cash deposit issue, examined supporting records, and accepted one permissible view of the evidence. The Commissioner cannot substitute a different opinion or rely on an audit objection and a reappraisal of the same material unless there is a clear, reasoned finding that the assessment order is both erroneous and prejudicial to the interests of revenue. Mere desire for further enquiry, or an allegation of inadequate enquiry without demonstrating error in the assessment, does not confer revisionary jurisdiction. The original assessment was therefore not capable of revision on the facts found. Case-Laws Income Tax Thu, 06 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=333947