https://www.taxtmi.com/caselaws?id=306894 Section 263 revision was unsustainable where the Commissioner did not consider the assessee's explanation or make the inquiry needed before treating the assessment as erroneous and prejudicial to Revenue. The assessment under section 143(3) had accepted the returned income, but the revisional authority proceeded on the assumption that development fees were taxable revenue income without examining the assessee's case on capital expenditure and application of income. On the record, those factors could alter the tax result, so the necessary factual inquiry was absent and the revision failed. en-us Thu, 02 Mar 2023 00:00:00 +0530 Mon, 02 Dec 2024 18:31:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306894 Section 263 revision was unsustainable where the Commissioner did not consider the assessee's explanation or make the inquiry needed before treating the assessment as erroneous and prejudicial to Revenue. The assessment under section 143(3) had accepted the returned income, but the revisional authority proceeded on the assumption that development fees were taxable revenue income without examining the assessee's case on capital expenditure and application of income. On the record, those factors could alter the tax result, so the necessary factual inquiry was absent and the revision failed. Case-Laws Income Tax Thu, 02 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306894