https://www.taxtmi.com/caselaws?id=793347 Section 263 revision requires an assessment order to be both erroneous and prejudicial to Revenue interests. Where the Assessing Officer has made enquiries into investment and dividend transactions and adopted a lawful plausible view that they were genuine, revisional intervention cannot rest solely on a different opinion. Mutual fund investments cannot be characterised as sham without cogent material showing the investor's conscious participation in a colourable device or prior knowledge of the alleged methodology. Statutory dividend exemption and capital-loss relief remained available because the transaction fell outside the relevant anti-avoidance rule. Directions concerning a subsequent assessment year exceeded the revisional scope. The reassessment order was restored and the revisional order quashed. en-us Fri, 29 May 2026 00:00:00 +0530 Sat, 13 Jun 2026 08:36:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793347 Section 263 revision requires an assessment order to be both erroneous and prejudicial to Revenue interests. Where the Assessing Officer has made enquiries into investment and dividend transactions and adopted a lawful plausible view that they were genuine, revisional intervention cannot rest solely on a different opinion. Mutual fund investments cannot be characterised as sham without cogent material showing the investor's conscious participation in a colourable device or prior knowledge of the alleged methodology. Statutory dividend exemption and capital-loss relief remained available because the transaction fell outside the relevant anti-avoidance rule. Directions concerning a subsequent assessment year exceeded the revisional scope. The reassessment order was restored and the revisional order quashed. Case-Laws Income Tax Fri, 29 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793347