https://www.taxtmi.com/caselaws?id=468932 Section 263 revision could not be used to expand a limited-scrutiny reassessment confined to deemed dividend under section 2(22)(e). The Assessing Officer had examined the recorded issue, considered the assessee's explanation and made an addition on that basis, so the reassessment order was not shown to be erroneous on the matter actually reopened. Issues of cash deposits and purchase of immovable properties fell outside the original limited-scrutiny scope and could not justify revision on facts not forming part of the reassessment record. The Principal Commissioner's invocation of section 263 was therefore held unwarranted, and the revisionary order was set aside. en-us Wed, 27 Aug 2025 00:00:00 +0530 Mon, 25 May 2026 20:05:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468932 Section 263 revision could not be used to expand a limited-scrutiny reassessment confined to deemed dividend under section 2(22)(e). The Assessing Officer had examined the recorded issue, considered the assessee's explanation and made an addition on that basis, so the reassessment order was not shown to be erroneous on the matter actually reopened. Issues of cash deposits and purchase of immovable properties fell outside the original limited-scrutiny scope and could not justify revision on facts not forming part of the reassessment record. The Principal Commissioner's invocation of section 263 was therefore held unwarranted, and the revisionary order was set aside. Case-Laws Income Tax Wed, 27 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468932