https://www.taxtmi.com/highlights?id=96953 Revision under Section 263 was held vitiated where the revisional opinion reallocating R&D expenditure to eligible undertakings rested on presumption and conjecture rather than concrete evidence; the Assessing Officer had conducted a full enquiry and permissibly allowed the R&D deduction. The Tribunal found the revisionary exercise to be materially influenced by an audit objection and not an independent satisfaction, quashed the revision order and restored the assessment order of the AO, allowing the assessee's appeal. en-us Tue, 17 Feb 2026 10:11:48 +0530 Tue, 17 Feb 2026 10:11:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=96953 Revision under Section 263 was held vitiated where the revisional opinion reallocating R&D expenditure to eligible undertakings rested on presumption and conjecture rather than concrete evidence; the Assessing Officer had conducted a full enquiry and permissibly allowed the R&D deduction. The Tribunal found the revisionary exercise to be materially influenced by an audit objection and not an independent satisfaction, quashed the revision order and restored the assessment order of the AO, allowing the assessee's appeal. Highlights Income Tax Tue, 17 Feb 2026 10:11:48 +0530 https://www.taxtmi.com/highlights?id=96953