https://www.taxtmi.com/caselaws?id=759314 Section 263 revision cannot be sustained where the Assessing Officer has examined the return, schedules and replies, and specifically enquired into set-off of brought-forward losses and unabsorbed depreciation. The governing test requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue; a mere difference of opinion or alleged inadequacy of enquiry is insufficient if the Assessing Officer has applied his mind to the issue. On the facts, the record showed enquiry rather than a complete absence of it, so the revisionary order was unsustainable. en-us Thu, 29 Aug 2024 00:00:00 +0530 Sat, 28 Sep 2024 08:11:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759314 Section 263 revision cannot be sustained where the Assessing Officer has examined the return, schedules and replies, and specifically enquired into set-off of brought-forward losses and unabsorbed depreciation. The governing test requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue; a mere difference of opinion or alleged inadequacy of enquiry is insufficient if the Assessing Officer has applied his mind to the issue. On the facts, the record showed enquiry rather than a complete absence of it, so the revisionary order was unsustainable. Case-Laws Income Tax Thu, 29 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759314