https://www.taxtmi.com/caselaws?id=303441 Revision under section 263 was not justified where the Assessing Officer had made specific enquiries on TDS, obtained replies and supporting material, and independently verified the payees' confirmations. On those facts, the payments were treated as supplies of earth, mitti and stones rather than contract, sub-contract or commission payments, so sections 194C and 194H were held inapplicable and section 40(a)(ia) was not attracted. The Commissioner could not revise the assessment merely because a different inference was possible or because every investigative step was not expressly discussed in the order. Initiation of penalty proceedings under section 271C did not support revision on the disallowance issue. en-us Mon, 30 Nov 2015 00:00:00 +0530 Sat, 23 Jul 2022 09:01:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=303441 Revision under section 263 was not justified where the Assessing Officer had made specific enquiries on TDS, obtained replies and supporting material, and independently verified the payees' confirmations. On those facts, the payments were treated as supplies of earth, mitti and stones rather than contract, sub-contract or commission payments, so sections 194C and 194H were held inapplicable and section 40(a)(ia) was not attracted. The Commissioner could not revise the assessment merely because a different inference was possible or because every investigative step was not expressly discussed in the order. Initiation of penalty proceedings under section 271C did not support revision on the disallowance issue. Case-Laws Income Tax Mon, 30 Nov 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=303441