https://www.taxtmi.com/caselaws?id=469838 Revision under section 263 is available only where the assessment order is both erroneous and prejudicial to the interests of Revenue, and interference is generally unwarranted if the Assessing Officer has taken one of two plausible views after enquiry. Here, the Assessing Officer had not examined the allowability of patent fees paid to a subsidiary as revenue expenditure, and the omission was treated as lack of enquiry within Explanation 2 to section 263. On that basis, supervisory revision was justified and the challenge to the revisionary order failed. en-us Tue, 11 Mar 2025 00:00:00 +0530 Mon, 06 Jul 2026 20:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469838 Revision under section 263 is available only where the assessment order is both erroneous and prejudicial to the interests of Revenue, and interference is generally unwarranted if the Assessing Officer has taken one of two plausible views after enquiry. Here, the Assessing Officer had not examined the allowability of patent fees paid to a subsidiary as revenue expenditure, and the omission was treated as lack of enquiry within Explanation 2 to section 263. On that basis, supervisory revision was justified and the challenge to the revisionary order failed. Case-Laws Income Tax Tue, 11 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469838