https://www.taxtmi.com/caselaws?id=431560 Section 263 revision was invalid where the assessment record showed that the Assessing Officer had issued notices, sought details and examined the relevant income computation; a mere allegation of lack of enquiry could not establish error and prejudice to the Revenue. The explanation to section 263 could not be applied without a factual basis showing absence of enquiry, so the revision failed on jurisdiction. On the merits, income and surplus reflected in a life insurance company's shareholders' account formed part of life insurance business and had to be computed under section 44 and the First Schedule, not taxed separately at the normal corporate rate. The revision was therefore unsustainable. en-us Mon, 31 Oct 2022 00:00:00 +0530 Thu, 15 Dec 2022 16:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=431560 Section 263 revision was invalid where the assessment record showed that the Assessing Officer had issued notices, sought details and examined the relevant income computation; a mere allegation of lack of enquiry could not establish error and prejudice to the Revenue. The explanation to section 263 could not be applied without a factual basis showing absence of enquiry, so the revision failed on jurisdiction. On the merits, income and surplus reflected in a life insurance company's shareholders' account formed part of life insurance business and had to be computed under section 44 and the First Schedule, not taxed separately at the normal corporate rate. The revision was therefore unsustainable. Case-Laws Income Tax Mon, 31 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=431560