https://www.taxtmi.com/caselaws?id=304917 Revision under section 263 requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. Applying the amended section 115BBE rate to surrendered income was debatable because the assessment had not invoked sections 68 to 69D. Where two interpretations are possible, revision cannot substitute the Principal Commissioner's preferred view for the Assessing Officer's view. The distinction between lack of inquiry and inadequate inquiry also prevents revision merely because a different conclusion is considered preferable. Consequently, revisionary jurisdiction could not validly be exercised on this basis, and the revision order was unsustainable. en-us Wed, 24 Aug 2022 00:00:00 +0530 Sat, 05 Nov 2022 08:28:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=304917 Revision under section 263 requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. Applying the amended section 115BBE rate to surrendered income was debatable because the assessment had not invoked sections 68 to 69D. Where two interpretations are possible, revision cannot substitute the Principal Commissioner's preferred view for the Assessing Officer's view. The distinction between lack of inquiry and inadequate inquiry also prevents revision merely because a different conclusion is considered preferable. Consequently, revisionary jurisdiction could not validly be exercised on this basis, and the revision order was unsustainable. Case-Laws Income Tax Wed, 24 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=304917