https://www.taxtmi.com/caselaws?id=786889 Revisional power under Section 263 is exercisable only where the revising authority records material and reasoned findings showing the subordinate order is prima facie erroneous and prejudicial; absent such material, revision cannot substitute the Assessing Officer's considered view. Applying this, the tribunal found the funds to be equity-oriented and taxable as long-term capital gains under Section 112A, upheld the Assessing Officer's acceptance of declared Annual Letting Value for specified properties, and held that directing initiation of penalty proceedings was not sustainable where no material justified revisional interference. en-us Mon, 16 Feb 2026 00:00:00 +0530 Sat, 21 Feb 2026 09:29:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786889 Revisional power under Section 263 is exercisable only where the revising authority records material and reasoned findings showing the subordinate order is prima facie erroneous and prejudicial; absent such material, revision cannot substitute the Assessing Officer's considered view. Applying this, the tribunal found the funds to be equity-oriented and taxable as long-term capital gains under Section 112A, upheld the Assessing Officer's acceptance of declared Annual Letting Value for specified properties, and held that directing initiation of penalty proceedings was not sustainable where no material justified revisional interference. Case-Laws Income Tax Mon, 16 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786889