https://www.taxtmi.com/caselaws?id=6126 SC held that the Commissioner's revision under section 263 was invalid because he recorded no reasons showing the Assessing Officer erred in treating the power subsidy as a capital receipt. At the time the power was exercised, the jurisdictional HC's decision treating the subsidy as capital was operative, and the AO had properly acted on that decision. A later reversal by the SC could not retroactively justify treating the AO's conduct as erroneous. The Commissioner thus lacked the requisite material-legal or factual-to exercise jurisdiction under section 263. en-us Tue, 10 Dec 2002 00:00:00 +0530 Wed, 05 Nov 2025 12:22:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6126 SC held that the Commissioner's revision under section 263 was invalid because he recorded no reasons showing the Assessing Officer erred in treating the power subsidy as a capital receipt. At the time the power was exercised, the jurisdictional HC's decision treating the subsidy as capital was operative, and the AO had properly acted on that decision. A later reversal by the SC could not retroactively justify treating the AO's conduct as erroneous. The Commissioner thus lacked the requisite material-legal or factual-to exercise jurisdiction under section 263. Case-Laws Income Tax Tue, 10 Dec 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6126