https://www.taxtmi.com/caselaws?id=470009 Revision under Section 263 cannot rest on the incorrect factual premise that an assessee failed to intimate its settlement application where Form No. 34BA was furnished as required. For completed assessments reopened under Section 153C, additions are confined to incriminating material found during search; an estimated disclosure made for settlement purposes is not, by itself, seized incriminating material. For a regular assessment, revision also fails where the alleged non-disclosure is factually wrong and no other assessment error is identified. Consequently, revision orders founded solely on that premise, and consequential fresh assessments and appellate orders, lack legal basis. en-us Fri, 22 Mar 2024 00:00:00 +0530 Mon, 13 Jul 2026 13:15:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470009 Revision under Section 263 cannot rest on the incorrect factual premise that an assessee failed to intimate its settlement application where Form No. 34BA was furnished as required. For completed assessments reopened under Section 153C, additions are confined to incriminating material found during search; an estimated disclosure made for settlement purposes is not, by itself, seized incriminating material. For a regular assessment, revision also fails where the alleged non-disclosure is factually wrong and no other assessment error is identified. Consequently, revision orders founded solely on that premise, and consequential fresh assessments and appellate orders, lack legal basis. Case-Laws Income Tax Fri, 22 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470009