https://www.taxtmi.com/caselaws?id=796491 Revision under section 263 requires a demonstrated error that is prejudicial to Revenue and cannot rest on reappreciation of material already examined during limited scrutiny. The ITAT found that reconciliations and supporting records addressed TDS credit, professional receipts and payout advances, including external-counsel amounts not constituting the assessee's income; revision was therefore invalid. The difference between Form 3CD and book expenditure was reconciled as gross TDS-reporting payments versus net expenditure, with no resulting prejudice; revision also failed on that ground. Expanding beyond the show cause notice through vague directions for broad verification constituted an impermissible roving reassessment. The revisionary order was set aside and the original assessment restored. en-us Tue, 20 Jan 2026 00:00:00 +0530 Thu, 06 Aug 2026 09:11:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796491 Revision under section 263 requires a demonstrated error that is prejudicial to Revenue and cannot rest on reappreciation of material already examined during limited scrutiny. The ITAT found that reconciliations and supporting records addressed TDS credit, professional receipts and payout advances, including external-counsel amounts not constituting the assessee's income; revision was therefore invalid. The difference between Form 3CD and book expenditure was reconciled as gross TDS-reporting payments versus net expenditure, with no resulting prejudice; revision also failed on that ground. Expanding beyond the show cause notice through vague directions for broad verification constituted an impermissible roving reassessment. The revisionary order was set aside and the original assessment restored. Case-Laws Income Tax Tue, 20 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796491