https://www.taxtmi.com/caselaws?id=467454 The note addresses whether invoking revisionary powers under section 263 was justified where the Assessing Officer issued specific TDS enquiries, received reconciliations, lower withholding certificates and explanations (treaty relief, threshold exemptions) and applied his mind at assessment under section 143(3). It restates the principle that revision is available only where an assessment order is legally erroneous or there is a genuine lack of inquiry such that the assessment is not in accordance with law; mere inadequacy of inquiry or difference of opinion does not permit substitution of the AO's judgment. On the stated facts the revision invocation was found unwarranted. en-us Wed, 25 Jan 2023 00:00:00 +0530 Thu, 19 Mar 2026 15:08:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467454 The note addresses whether invoking revisionary powers under section 263 was justified where the Assessing Officer issued specific TDS enquiries, received reconciliations, lower withholding certificates and explanations (treaty relief, threshold exemptions) and applied his mind at assessment under section 143(3). It restates the principle that revision is available only where an assessment order is legally erroneous or there is a genuine lack of inquiry such that the assessment is not in accordance with law; mere inadequacy of inquiry or difference of opinion does not permit substitution of the AO's judgment. On the stated facts the revision invocation was found unwarranted. Case-Laws Income Tax Wed, 25 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467454