https://www.taxtmi.com/caselaws?id=786651 Question whether a revisional order under Section 263 setting aside an assessment under Section 143(3) r.w.s. 144B is sustainable where the Assessing Officer issued repeated Section 142(1) notices and considered detailed submissions. Principle applied: Section 263 requires the Commissioner to record clear prima facie reasons that the assessment order is both erroneous and prejudicial to revenue; mere disagreement with an AO who applied his mind does not suffice. The authority cannot order a roving inquiry or remand without demonstrating specific errors and quantifying any excessive related party payments against fair market value. Outcome: the revisional order was set aside and the AO's assessment restored. en-us Wed, 28 Jan 2026 00:00:00 +0530 Fri, 13 Feb 2026 18:57:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786651 Question whether a revisional order under Section 263 setting aside an assessment under Section 143(3) r.w.s. 144B is sustainable where the Assessing Officer issued repeated Section 142(1) notices and considered detailed submissions. Principle applied: Section 263 requires the Commissioner to record clear prima facie reasons that the assessment order is both erroneous and prejudicial to revenue; mere disagreement with an AO who applied his mind does not suffice. The authority cannot order a roving inquiry or remand without demonstrating specific errors and quantifying any excessive related party payments against fair market value. Outcome: the revisional order was set aside and the AO's assessment restored. Case-Laws Income Tax Wed, 28 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786651