https://www.taxtmi.com/caselaws?id=469550 An assessment order passed without any inquiry into a material issue, including the taxability of an opening Foreign Currency Translation Reserve and the effect of CBDT Circular No. 10/2017, is erroneous and prejudicial to the interests of the revenue and may be revised under section 263. However, when the matter is remitted for fresh adjudication, the revisional authority should not record conclusive adverse findings on merits, because substantive issues must remain open for the Assessing Officer's de novo consideration. The assessment was therefore remitted for fresh decision with the merits-based observations vacated, and the appeal succeeded only to that limited extent. en-us Tue, 08 Mar 2022 00:00:00 +0530 Mon, 22 Jun 2026 15:35:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469550 An assessment order passed without any inquiry into a material issue, including the taxability of an opening Foreign Currency Translation Reserve and the effect of CBDT Circular No. 10/2017, is erroneous and prejudicial to the interests of the revenue and may be revised under section 263. However, when the matter is remitted for fresh adjudication, the revisional authority should not record conclusive adverse findings on merits, because substantive issues must remain open for the Assessing Officer's de novo consideration. The assessment was therefore remitted for fresh decision with the merits-based observations vacated, and the appeal succeeded only to that limited extent. Case-Laws Income Tax Tue, 08 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469550