https://www.taxtmi.com/caselaws?id=429698 Section 263 revision was invalid where the Assessing Officer had examined the survey material, considered the excess stock discrepancy, and adopted the plausible view that the disclosed amount constituted business income. The Principal Commissioner could not invoke revision merely to recharacterise the same facts as unexplained investment under section 69 read with section 115BBE, because Explanation 2 to section 263 does not permit interference when enquiry was made and a sustainable view was taken. In the absence of independent material showing a real error of fact or law causing prejudice to the Revenue, the revisional order was quashed and the assessment was left undisturbed. en-us Fri, 21 Oct 2022 00:00:00 +0530 Wed, 02 Nov 2022 15:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=429698 Section 263 revision was invalid where the Assessing Officer had examined the survey material, considered the excess stock discrepancy, and adopted the plausible view that the disclosed amount constituted business income. The Principal Commissioner could not invoke revision merely to recharacterise the same facts as unexplained investment under section 69 read with section 115BBE, because Explanation 2 to section 263 does not permit interference when enquiry was made and a sustainable view was taken. In the absence of independent material showing a real error of fact or law causing prejudice to the Revenue, the revisional order was quashed and the assessment was left undisturbed. Case-Laws Income Tax Fri, 21 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=429698