https://www.taxtmi.com/highlights?id=96712 Revision under section 263 was denied because the assessing officer adopted a legally permissible view in treating a 5.24% difference between stamp duty value and sale consideration as non-taxable; such a view is not "erroneous and prejudicial to the interests of revenue" and therefore cannot be reopened as a change of opinion. The article holds that statutory tolerance bands introduced by later Finance Acts (5% then 10%) should be given retrospective, beneficial construction to mitigate hardship, and hence the impugned exercise of revisional power was quashed and relief granted to the assessee. en-us Mon, 09 Feb 2026 09:18:00 +0530 Mon, 09 Feb 2026 09:18:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=96712 Revision under section 263 was denied because the assessing officer adopted a legally permissible view in treating a 5.24% difference between stamp duty value and sale consideration as non-taxable; such a view is not "erroneous and prejudicial to the interests of revenue" and therefore cannot be reopened as a change of opinion. The article holds that statutory tolerance bands introduced by later Finance Acts (5% then 10%) should be given retrospective, beneficial construction to mitigate hardship, and hence the impugned exercise of revisional power was quashed and relief granted to the assessee. Highlights Income Tax Mon, 09 Feb 2026 09:18:00 +0530 https://www.taxtmi.com/highlights?id=96712