https://www.taxtmi.com/caselaws?id=412822 Section 263 revision is available only where the assessment order is both erroneous and prejudicial to the Revenue. Where the Assessing Officer issues specific queries, calls for supporting documents, and examines purchase, sale, demat and bank records before accepting a loss claim, the assessment cannot be treated as one passed without enquiry or application of mind. A different view by the Principal Commissioner is not enough to justify revision, and unsupported allegations that the shares were penny stocks do not establish that the assessment was unsustainable in law. On these facts, invocation of section 263 was invalid and the revisional order lacked jurisdiction. en-us Fri, 17 Sep 2021 00:00:00 +0530 Tue, 28 Sep 2021 06:58:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=412822 Section 263 revision is available only where the assessment order is both erroneous and prejudicial to the Revenue. Where the Assessing Officer issues specific queries, calls for supporting documents, and examines purchase, sale, demat and bank records before accepting a loss claim, the assessment cannot be treated as one passed without enquiry or application of mind. A different view by the Principal Commissioner is not enough to justify revision, and unsupported allegations that the shares were penny stocks do not establish that the assessment was unsustainable in law. On these facts, invocation of section 263 was invalid and the revisional order lacked jurisdiction. Case-Laws Income Tax Fri, 17 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=412822