https://www.taxtmi.com/caselaws?id=787627 Whether revision under Section 263 was justified turned on the statutory twin conditions: the primary legal question was whether the assessment order was both erroneous and prejudicial to revenue and whether the AO failed to make required inquiries (Explanation 2(a)). The tribunal reasoned that where the AO considered circle rates, examined a registered valuer's report, and applied his mind to adopt an estimative fair market value for capital gains computation, a mere post facto preference for a DVO figure does not satisfy Section 263. Outcome: the Section 263 revision was set aside because both statutory conditions were not concurrently met. en-us Fri, 06 Mar 2026 00:00:00 +0530 Tue, 10 Mar 2026 08:51:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787627 Whether revision under Section 263 was justified turned on the statutory twin conditions: the primary legal question was whether the assessment order was both erroneous and prejudicial to revenue and whether the AO failed to make required inquiries (Explanation 2(a)). The tribunal reasoned that where the AO considered circle rates, examined a registered valuer's report, and applied his mind to adopt an estimative fair market value for capital gains computation, a mere post facto preference for a DVO figure does not satisfy Section 263. Outcome: the Section 263 revision was set aside because both statutory conditions were not concurrently met. Case-Laws Income Tax Fri, 06 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787627