https://www.taxtmi.com/caselaws?id=466966 Revisional jurisdiction under section 263 cannot be invoked to direct inquiry and additions on income (interest) that was not included in the original section 148 notice where the Assessing Officer accepted the assessee's explanation on the reopening reason and made no addition. The twin conditions for exercise of section 263 (order erroneous and prejudicial to revenue) and the limits imposed by Explanation 3 to section 147 require that other income discovered during reassessment may be assessed only if the income that prompted reopening remains part of the reassessed income or a fresh valid notice is issued; absent that, the revisional direction is unsustainable. en-us Wed, 18 Sep 2024 00:00:00 +0530 Fri, 27 Feb 2026 16:36:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466966 Revisional jurisdiction under section 263 cannot be invoked to direct inquiry and additions on income (interest) that was not included in the original section 148 notice where the Assessing Officer accepted the assessee's explanation on the reopening reason and made no addition. The twin conditions for exercise of section 263 (order erroneous and prejudicial to revenue) and the limits imposed by Explanation 3 to section 147 require that other income discovered during reassessment may be assessed only if the income that prompted reopening remains part of the reassessed income or a fresh valid notice is issued; absent that, the revisional direction is unsustainable. Case-Laws Income Tax Wed, 18 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466966