https://www.taxtmi.com/caselaws?id=313033 ITAT Jaipur held that section 263 revision cannot be invoked merely for change of opinion. The provision requires an order to be both erroneous and prejudicial to revenue interest. Where AO adopted a permissible course after examining books of accounts and documents, recording satisfaction after verification, the order cannot be revised under section 263. Even if AO's view differs from Pr. CIT's preference, it doesn't constitute an erroneous order unless the view is totally unsustainable in law. The appeal was allowed, emphasizing that loss of revenue alone doesn't justify revision proceedings. en-us Mon, 29 Aug 2022 00:00:00 +0530 Wed, 20 Mar 2024 13:57:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313033 ITAT Jaipur held that section 263 revision cannot be invoked merely for change of opinion. The provision requires an order to be both erroneous and prejudicial to revenue interest. Where AO adopted a permissible course after examining books of accounts and documents, recording satisfaction after verification, the order cannot be revised under section 263. Even if AO's view differs from Pr. CIT's preference, it doesn't constitute an erroneous order unless the view is totally unsustainable in law. The appeal was allowed, emphasizing that loss of revenue alone doesn't justify revision proceedings. Case-Laws Income Tax Mon, 29 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313033