https://www.taxtmi.com/caselaws?id=786995 Treatment of revisional jurisdiction under Section 263 is constrained where the Assessing Officer conducted inquiries, considered documentary material and followed applicable administrative instructions; mere brevity of reasoning does not establish error or prejudice and jurisdiction cannot be exercised solely because a superior authority disagrees. A post hoc conversion of stock in trade into a capital asset raised at appellate stage is impermissible absent prior findings; isolated, long held transactions without trading pattern do not support conversion. Surplus on sale of unlisted preference shares held to be long term capital gain based on intention at acquisition, holding period, solitary sale and accounting treatment. Paragraph 3(b) of Circular No.6/2016 inapplicable to unlisted shares. en-us Fri, 20 Feb 2026 00:00:00 +0530 Tue, 24 Feb 2026 08:36:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786995 Treatment of revisional jurisdiction under Section 263 is constrained where the Assessing Officer conducted inquiries, considered documentary material and followed applicable administrative instructions; mere brevity of reasoning does not establish error or prejudice and jurisdiction cannot be exercised solely because a superior authority disagrees. A post hoc conversion of stock in trade into a capital asset raised at appellate stage is impermissible absent prior findings; isolated, long held transactions without trading pattern do not support conversion. Surplus on sale of unlisted preference shares held to be long term capital gain based on intention at acquisition, holding period, solitary sale and accounting treatment. Paragraph 3(b) of Circular No.6/2016 inapplicable to unlisted shares. Case-Laws Income Tax Fri, 20 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786995