https://www.taxtmi.com/caselaws?id=290756 Section 263 revision is not barred merely because an appeal against the assessment is pending; the pendency of appellate proceedings does not, by itself, remove revisional jurisdiction. However, the Commissioner must still have objective material showing that the assessment order is both erroneous and prejudicial to the interests of the revenue. On the facts noted, the officer had followed the appellate and tribunal view on identical facts, and no sufficient basis was shown to disturb that approach. The consequential rejection of the Section 264 application, being founded on the revisional action, could not stand once the revision was treated as without jurisdiction. en-us Thu, 06 May 1976 00:00:00 +0530 Thu, 15 Oct 2020 10:05:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=290756 Section 263 revision is not barred merely because an appeal against the assessment is pending; the pendency of appellate proceedings does not, by itself, remove revisional jurisdiction. However, the Commissioner must still have objective material showing that the assessment order is both erroneous and prejudicial to the interests of the revenue. On the facts noted, the officer had followed the appellate and tribunal view on identical facts, and no sufficient basis was shown to disturb that approach. The consequential rejection of the Section 264 application, being founded on the revisional action, could not stand once the revision was treated as without jurisdiction. Case-Laws Income Tax Thu, 06 May 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=290756