https://www.taxtmi.com/caselaws?id=787605 Revision under Section 263 requires a demonstrable error in the assessment record that is also prejudicial to Revenue; absent such factual error revision cannot be sustained. On the facts, no return or assessment record showed a Section 44AD declaration or claims for the contested car-related deductions, so disallowance was not warranted. The forfeited earnest money deposit arose from recurring participation in e-auctions and was recorded as supply-related charges, making it revenue in nature rather than capital. Consequently the twin conditions for invoking revision were not met; the Section 263 order was quashed and the appeal allowed for the assessee. en-us Wed, 07 Jan 2026 00:00:00 +0530 Tue, 10 Mar 2026 08:51:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787605 Revision under Section 263 requires a demonstrable error in the assessment record that is also prejudicial to Revenue; absent such factual error revision cannot be sustained. On the facts, no return or assessment record showed a Section 44AD declaration or claims for the contested car-related deductions, so disallowance was not warranted. The forfeited earnest money deposit arose from recurring participation in e-auctions and was recorded as supply-related charges, making it revenue in nature rather than capital. Consequently the twin conditions for invoking revision were not met; the Section 263 order was quashed and the appeal allowed for the assessee. Case-Laws Income Tax Wed, 07 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787605