https://www.taxtmi.com/caselaws?id=769223 SC dismissed the special leave petition, upholding HC and ITAT that the revision under section 263 was unsustainable where the AO had made inquiries but reached a different conclusion. The Court held there is a clear distinction between absence/failure of investigation and a wrong decision; s.263 may be used to correct a wrong conclusion by making additions on merits, but cannot be invoked simply because the AO could have made further enquiries. Remand is permissible only where the AO's investigation was abjectly deficient and caused error prejudicial to revenue. en-us Fri, 04 Apr 2025 00:00:00 +0530 Fri, 05 Sep 2025 14:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769223 SC dismissed the special leave petition, upholding HC and ITAT that the revision under section 263 was unsustainable where the AO had made inquiries but reached a different conclusion. The Court held there is a clear distinction between absence/failure of investigation and a wrong decision; s.263 may be used to correct a wrong conclusion by making additions on merits, but cannot be invoked simply because the AO could have made further enquiries. Remand is permissible only where the AO's investigation was abjectly deficient and caused error prejudicial to revenue. Case-Laws Income Tax Fri, 04 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769223