https://www.taxtmi.com/caselaws?id=468897 Revision under section 263 of the Income-tax Act cannot rest on material not forming part of the assessment record. The ITAT Ahmedabad held that where the alleged defect in the assessment was based on a DVO valuation report received only after completion of the assessment, the Commissioner could not treat the assessment as erroneous and prejudicial to the interests of revenue on that basis. Since the report was unavailable to the Assessing Officer when the assessment was made, it could not found revisionary jurisdiction. The revisionary order was therefore unsustainable and was quashed. en-us Fri, 20 Oct 2023 00:00:00 +0530 Mon, 25 May 2026 17:17:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468897 Revision under section 263 of the Income-tax Act cannot rest on material not forming part of the assessment record. The ITAT Ahmedabad held that where the alleged defect in the assessment was based on a DVO valuation report received only after completion of the assessment, the Commissioner could not treat the assessment as erroneous and prejudicial to the interests of revenue on that basis. Since the report was unavailable to the Assessing Officer when the assessment was made, it could not found revisionary jurisdiction. The revisionary order was therefore unsustainable and was quashed. Case-Laws Income Tax Fri, 20 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468897