https://www.taxtmi.com/caselaws?id=402322 ITAT MUMBAI - AT held that the Commissioner's revision under s.263 was unjustified and set aside the revision order. The Tribunal explained Explanation 2(a) requires an objective finding that the AO failed to make inquiries a prudent officer would make; mere allegation is insufficient. Only where lack of inquiry prevents any conclusive finding can revision be ordered. Here the AO had examined investments, payments and records (including financial schedules and Form 26AS), no prejudice to revenue was shown, and alleged non-verifications did not warrant revision. Decision in favour of the assessee trust. en-us Mon, 28 Dec 2020 00:00:00 +0530 Fri, 14 Nov 2025 16:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=402322 ITAT MUMBAI - AT held that the Commissioner's revision under s.263 was unjustified and set aside the revision order. The Tribunal explained Explanation 2(a) requires an objective finding that the AO failed to make inquiries a prudent officer would make; mere allegation is insufficient. Only where lack of inquiry prevents any conclusive finding can revision be ordered. Here the AO had examined investments, payments and records (including financial schedules and Form 26AS), no prejudice to revenue was shown, and alleged non-verifications did not warrant revision. Decision in favour of the assessee trust. Case-Laws Income Tax Mon, 28 Dec 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=402322