https://www.taxtmi.com/caselaws?id=796605 Revision under Section 263 is unavailable for purchase disallowances already forming part of a pending first appeal, as the revisionary power is confined to matters not considered and decided in that appeal. The notes further state that an assessment based on examination of purchase records, payment evidence, transport documents, confirmations and GST material cannot be revised merely because the revisional authority prefers full disallowance as unexplained expenditure over profit estimation. An outstanding supplier liability does not amount to remission or cessation without evidence of write-back, waiver, remission or cessation during the relevant year. Revisionary jurisdiction cannot substitute a different view for a plausible view adopted after inquiry. en-us Tue, 04 Aug 2026 00:00:00 +0530 Fri, 07 Aug 2026 09:07:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796605 Revision under Section 263 is unavailable for purchase disallowances already forming part of a pending first appeal, as the revisionary power is confined to matters not considered and decided in that appeal. The notes further state that an assessment based on examination of purchase records, payment evidence, transport documents, confirmations and GST material cannot be revised merely because the revisional authority prefers full disallowance as unexplained expenditure over profit estimation. An outstanding supplier liability does not amount to remission or cessation without evidence of write-back, waiver, remission or cessation during the relevant year. Revisionary jurisdiction cannot substitute a different view for a plausible view adopted after inquiry. Case-Laws Income Tax Tue, 04 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796605