https://www.taxtmi.com/caselaws?id=758538 Revision under section 263 of the Income-tax Act is not justified unless the assessment order is both erroneous and prejudicial to the Revenue. Where the Assessing Officer issued notices, called for details, examined subcontracting expenditure, obtained a section 133(6) response, and completed reassessment after considering the material, mere inadequacy of enquiry does not permit revision. The Commissioner cannot substitute a different view on the same record, and the refund-related issue, being consequential to the reassessment, did not provide an independent basis for section 263 action. On these facts, the revisional order was not sustainable. en-us Wed, 28 Aug 2024 00:00:00 +0530 Sat, 14 Sep 2024 11:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758538 Revision under section 263 of the Income-tax Act is not justified unless the assessment order is both erroneous and prejudicial to the Revenue. Where the Assessing Officer issued notices, called for details, examined subcontracting expenditure, obtained a section 133(6) response, and completed reassessment after considering the material, mere inadequacy of enquiry does not permit revision. The Commissioner cannot substitute a different view on the same record, and the refund-related issue, being consequential to the reassessment, did not provide an independent basis for section 263 action. On these facts, the revisional order was not sustainable. Case-Laws Income Tax Wed, 28 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758538