https://www.taxtmi.com/caselaws?id=792292 Revision under Section 263 of the Income-tax Act, 1961 is permissible only when the assessment order is both erroneous and prejudicial to the interests of revenue. The HC held that the Principal Commissioner could not sustain revision on a mere change of opinion, particularly where the Tribunal had found the issue covered by the assessee's own case and the Assessing Officer had followed an earlier departmental view. The Revenue's reliance on a Supreme Court decision was found distinguishable on facts because that case involved a demonstrably erroneous and prejudicial assessment. No substantial question of law arose, and the Tribunal's order quashing the revision was left undisturbed. en-us Thu, 26 Feb 2026 00:00:00 +0530 Tue, 26 May 2026 08:24:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792292 Revision under Section 263 of the Income-tax Act, 1961 is permissible only when the assessment order is both erroneous and prejudicial to the interests of revenue. The HC held that the Principal Commissioner could not sustain revision on a mere change of opinion, particularly where the Tribunal had found the issue covered by the assessee's own case and the Assessing Officer had followed an earlier departmental view. The Revenue's reliance on a Supreme Court decision was found distinguishable on facts because that case involved a demonstrably erroneous and prejudicial assessment. No substantial question of law arose, and the Tribunal's order quashing the revision was left undisturbed. Case-Laws Income Tax Thu, 26 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792292