https://www.taxtmi.com/highlights?id=101684 Section 263 revision requires both inadequate enquiry and an unsustainable Assessing Officer view; where questionnaires, replies, office notes and correspondence show that issues were examined, revision cannot rest on mere disagreement. The notes further state that revision initiated through monitoring, pressure or dictates of higher departmental authorities is invalid where the assessments followed adequate enquiry, while other grounds may remain open. An interest-free advance to a wholly owned overseas subsidiary may constitute quasi-equity or shareholder funding, rather than a loan intended to earn interest, where it supports expansion and returns are expected through the assessee's business; a LIBOR-based adjustment is therefore unsusta..... en-us Tue, 14 Jul 2026 08:26:27 +0530 Tue, 14 Jul 2026 08:26:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=101684 Section 263 revision requires both inadequate enquiry and an unsustainable Assessing Officer view; where questionnaires, replies, office notes and correspondence show that issues were examined, revision cannot rest on mere disagreement. The notes further state that revision initiated through monitoring, pressure or dictates of higher departmental authorities is invalid where the assessments followed adequate enquiry, while other grounds may remain open. An interest-free advance to a wholly owned overseas subsidiary may constitute quasi-equity or shareholder funding, rather than a loan intended to earn interest, where it supports expansion and returns are expected through the assessee's business; a LIBOR-based adjustment is therefore unsusta..... Highlights Income Tax Tue, 14 Jul 2026 08:26:27 +0530 https://www.taxtmi.com/highlights?id=101684