https://www.taxtmi.com/caselaws?id=789776 Revision under section 263 is sustainable only where the assessment order is both erroneous and prejudicial to the Revenue; it cannot be used for a fresh or roving enquiry when the Assessing Officer has already examined the relevant material and adopted a permissible view. The Bombay HC noted that the assessee followed the project completion method, the accounting treatment had been accepted, and the occupancy certificate for the project had not been received in the relevant year. On that factual basis, the disputed on-money was not taxable in the year under appeal, and the revisional authority had no material to justify interference. The section 263 revision was therefore held unjustified. en-us Fri, 27 Mar 2026 00:00:00 +0530 Tue, 14 Apr 2026 08:03:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789776 Revision under section 263 is sustainable only where the assessment order is both erroneous and prejudicial to the Revenue; it cannot be used for a fresh or roving enquiry when the Assessing Officer has already examined the relevant material and adopted a permissible view. The Bombay HC noted that the assessee followed the project completion method, the accounting treatment had been accepted, and the occupancy certificate for the project had not been received in the relevant year. On that factual basis, the disputed on-money was not taxable in the year under appeal, and the revisional authority had no material to justify interference. The section 263 revision was therefore held unjustified. Case-Laws Income Tax Fri, 27 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789776