https://www.taxtmi.com/caselaws?id=304917 Section 263 revision cannot be invoked merely because the Principal Commissioner prefers a different view on taxing surrendered income under the amended section 115BBE. The article notes that applicability of the amended rate was treated as a highly debatable issue, especially where the assessment order did not invoke sections 68 to 69D to trigger section 115BBE. It reiterates that revision requires both error and prejudice to the Revenue, and that a debatable interpretation or a mere case of inadequate inquiry does not justify substitution of one possible view for another. On that basis, the revisionary assumption of jurisdiction was held 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 Section 263 revision cannot be invoked merely because the Principal Commissioner prefers a different view on taxing surrendered income under the amended section 115BBE. The article notes that applicability of the amended rate was treated as a highly debatable issue, especially where the assessment order did not invoke sections 68 to 69D to trigger section 115BBE. It reiterates that revision requires both error and prejudice to the Revenue, and that a debatable interpretation or a mere case of inadequate inquiry does not justify substitution of one possible view for another. On that basis, the revisionary assumption of jurisdiction was held unsustainable. Case-Laws Income Tax Wed, 24 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=304917