https://www.taxtmi.com/caselaws?id=796603 Revisionary jurisdiction under section 263 cannot be used to reopen an assessment merely because the revisional authority prefers a different view where the Assessing Officer made enquiries, considered the ESOP/ESAR deduction claim and adopted a legally sustainable position. The notes state that an admitted SLP against supporting precedent does not displace that precedent without a stay or reversal. As no specific enquiry defect or non-application of mind was identified, directing fresh verification amounted to an impermissible change of opinion. The section 263 conditions were therefore not met; the revisional order was quashed and the assessment restored. en-us Fri, 31 Jul 2026 00:00:00 +0530 Fri, 07 Aug 2026 09:07:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796603 Revisionary jurisdiction under section 263 cannot be used to reopen an assessment merely because the revisional authority prefers a different view where the Assessing Officer made enquiries, considered the ESOP/ESAR deduction claim and adopted a legally sustainable position. The notes state that an admitted SLP against supporting precedent does not displace that precedent without a stay or reversal. As no specific enquiry defect or non-application of mind was identified, directing fresh verification amounted to an impermissible change of opinion. The section 263 conditions were therefore not met; the revisional order was quashed and the assessment restored. Case-Laws Income Tax Fri, 31 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796603