https://www.taxtmi.com/caselaws?id=383097 A revision under section 263 was held unsustainable because the show-cause notice was issued and signed by an Income Tax Officer (Technical) on behalf of the Commissioner, although the revisional power vests only in the Commissioner and cannot be delegated to a subordinate officer. That defect was treated as jurisdictional and not curable. The revision also failed because the Assessing Officer had already examined the relevant material in the assessment under section 143(3) and taken a view, so the revisional action amounted only to a change of opinion or second opinion, which is impermissible under section 263. en-us Mon, 10 Jun 2019 00:00:00 +0530 Tue, 16 Jul 2019 18:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=383097 A revision under section 263 was held unsustainable because the show-cause notice was issued and signed by an Income Tax Officer (Technical) on behalf of the Commissioner, although the revisional power vests only in the Commissioner and cannot be delegated to a subordinate officer. That defect was treated as jurisdictional and not curable. The revision also failed because the Assessing Officer had already examined the relevant material in the assessment under section 143(3) and taken a view, so the revisional action amounted only to a change of opinion or second opinion, which is impermissible under section 263. Case-Laws Income Tax Mon, 10 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=383097