https://www.taxtmi.com/highlights?id=99519 Revision under section 263 was unwarranted where the Assessing Officer had examined the assessee's accumulation claim, Form No. 10, board resolutions and utilisation particulars, and had adopted a possible view on the material before him. The Commissioner could not invoke revision merely because he wanted deeper verification or considered another view preferable; absent independent demonstration that the assessment order was erroneous and prejudicial to revenue, the exercise amounted to an impermissible fishing enquiry. The Court also held that Explanation 2 to section 263 could not be applied without prior notice to the assessee. The alleged tax consequence of non-utilisation of accumulated income did not arise in the relevant assessment year. en-us Wed, 06 May 2026 08:32:10 +0530 Wed, 06 May 2026 08:32:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99519 Revision under section 263 was unwarranted where the Assessing Officer had examined the assessee's accumulation claim, Form No. 10, board resolutions and utilisation particulars, and had adopted a possible view on the material before him. The Commissioner could not invoke revision merely because he wanted deeper verification or considered another view preferable; absent independent demonstration that the assessment order was erroneous and prejudicial to revenue, the exercise amounted to an impermissible fishing enquiry. The Court also held that Explanation 2 to section 263 could not be applied without prior notice to the assessee. The alleged tax consequence of non-utilisation of accumulated income did not arise in the relevant assessment year. Highlights Income Tax Wed, 06 May 2026 08:32:10 +0530 https://www.taxtmi.com/highlights?id=99519