https://www.taxtmi.com/caselaws?id=468381 Revisional jurisdiction under section 263 cannot be sustained unless the assessment order is both erroneous and prejudicial to the interests of the Revenue. A revisional notice based on alleged failure to initiate penalty proceedings under section 271D was untenable because, at the time of assessment, the penalty power vested in the Joint Commissioner, not the Assessing Officer. A further challenge based on DVO valuation and search material also failed, as the assessment was made after considering the seized memorandum, sale deed, surrounding circumstances, sworn statement and DVO report; section 263 cannot be used to replace a plausible view with the Commissioner's preferred view. en-us Thu, 01 May 2025 00:00:00 +0530 Sun, 03 May 2026 22:20:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468381 Revisional jurisdiction under section 263 cannot be sustained unless the assessment order is both erroneous and prejudicial to the interests of the Revenue. A revisional notice based on alleged failure to initiate penalty proceedings under section 271D was untenable because, at the time of assessment, the penalty power vested in the Joint Commissioner, not the Assessing Officer. A further challenge based on DVO valuation and search material also failed, as the assessment was made after considering the seized memorandum, sale deed, surrounding circumstances, sworn statement and DVO report; section 263 cannot be used to replace a plausible view with the Commissioner's preferred view. Case-Laws Income Tax Thu, 01 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468381