https://www.taxtmi.com/caselaws?id=469066 Section 263 revision was tested against the requirement of error and prejudice where the Assessing Officer had already examined share premium, subscriber details, valuation report, ROC filings and related creditworthiness material. The record indicated that the receipts were explained as conversion of earlier unsecured loans into share application money and premium, with limited fresh inflow in the relevant year. Because the revisional authority did not show that the existing enquiries were legally insufficient or that the assessment view was unsustainable, the distinction between no enquiry and inadequate enquiry remained decisive. On that basis, revision could not rest on a mere difference of opinion, and the revisionary order was set aside. en-us Fri, 28 Mar 2025 00:00:00 +0530 Mon, 01 Jun 2026 18:58:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469066 Section 263 revision was tested against the requirement of error and prejudice where the Assessing Officer had already examined share premium, subscriber details, valuation report, ROC filings and related creditworthiness material. The record indicated that the receipts were explained as conversion of earlier unsecured loans into share application money and premium, with limited fresh inflow in the relevant year. Because the revisional authority did not show that the existing enquiries were legally insufficient or that the assessment view was unsustainable, the distinction between no enquiry and inadequate enquiry remained decisive. On that basis, revision could not rest on a mere difference of opinion, and the revisionary order was set aside. Case-Laws Income Tax Fri, 28 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469066