https://www.taxtmi.com/caselaws?id=767496 Revision under Section 263 of the Income-tax Act was not sustainable where the reassessment proceedings under Sections 148 and 143(3) had already examined the bank account issue and the claim under Section 10AA. The record showed that inquiry and verification were in fact made, so the Revenue's grievance was only with the conclusion reached in reassessment, not with any absence of inquiry. In that situation, Section 263 could be invoked only if the reassessment order was shown to be both erroneous and prejudicial to the interests of the Revenue on merits, and not as a mere substitution of opinion. en-us Mon, 17 Feb 2025 00:00:00 +0530 Wed, 19 Mar 2025 06:45:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767496 Revision under Section 263 of the Income-tax Act was not sustainable where the reassessment proceedings under Sections 148 and 143(3) had already examined the bank account issue and the claim under Section 10AA. The record showed that inquiry and verification were in fact made, so the Revenue's grievance was only with the conclusion reached in reassessment, not with any absence of inquiry. In that situation, Section 263 could be invoked only if the reassessment order was shown to be both erroneous and prejudicial to the interests of the Revenue on merits, and not as a mere substitution of opinion. Case-Laws Income Tax Mon, 17 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767496