https://www.taxtmi.com/caselaws?id=792756 Revision under section 263 is not justified where the Assessing Officer, in reassessment under section 144B read with section 147, examines the assessee's supporting material and accepts the returned income on the very issues that triggered reopening. The revisional authority cannot treat the order as erroneous merely because it believes further enquiry should have been made or prefers a different view. Explanation 2 to section 263 does not permit revision where enquiry was in fact conducted and a plausible view was taken. The critical distinction is between absence of enquiry and inadequate enquiry; once the issue has been examined, revision on a mere difference of opinion is impermissible. en-us Tue, 19 May 2026 00:00:00 +0530 Wed, 03 Jun 2026 08:50:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792756 Revision under section 263 is not justified where the Assessing Officer, in reassessment under section 144B read with section 147, examines the assessee's supporting material and accepts the returned income on the very issues that triggered reopening. The revisional authority cannot treat the order as erroneous merely because it believes further enquiry should have been made or prefers a different view. Explanation 2 to section 263 does not permit revision where enquiry was in fact conducted and a plausible view was taken. The critical distinction is between absence of enquiry and inadequate enquiry; once the issue has been examined, revision on a mere difference of opinion is impermissible. Case-Laws Income Tax Tue, 19 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792756