https://www.taxtmi.com/caselaws?id=25242 HC held that the Commissioner's revision under section 263 was unsustainable because he failed to identify any specific error in the ITO's orders; mere bare or detail-less orders do not establish an erroneous and prejudicial assessment. Absent a finding that income was understated, assessed on the wrong entity, taxed at an incorrect rate, or that an exemption was wrongly allowed, the Commissioner's conclusion rested on suspicion and surmise. The court declined to direct the Tribunal to state a case for the Revenue. en-us Fri, 30 Oct 1987 00:00:00 +0530 Wed, 29 Oct 2025 13:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=25242 HC held that the Commissioner's revision under section 263 was unsustainable because he failed to identify any specific error in the ITO's orders; mere bare or detail-less orders do not establish an erroneous and prejudicial assessment. Absent a finding that income was understated, assessed on the wrong entity, taxed at an incorrect rate, or that an exemption was wrongly allowed, the Commissioner's conclusion rested on suspicion and surmise. The court declined to direct the Tribunal to state a case for the Revenue. Case-Laws Income Tax Fri, 30 Oct 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=25242