https://www.taxtmi.com/caselaws?id=797080 Revisionary jurisdiction under Section 263 requires an assessment order to be both erroneous and prejudicial to the Revenue. Examination of the assessment record showed that the Assessing Officer had obtained and considered evidence of the non-resident shareholder's identity, financial capacity, audited financial statements, tax returns, remittance records and correspondence. Lack of detailed discussion in the assessment order did not prove absence of inquiry, and a permissible view taken after inquiry could not be revised merely because further inquiry was considered desirable. A direction for fresh examination required a clear finding of legal error supported by at least minimal independent inquiry. As no such error was established, the revisionary order was invalid and the direction to re-examine share capital was quashed. en-us Fri, 07 Aug 2026 00:00:00 +0530 Mon, 17 Aug 2026 08:38:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797080 Revisionary jurisdiction under Section 263 requires an assessment order to be both erroneous and prejudicial to the Revenue. Examination of the assessment record showed that the Assessing Officer had obtained and considered evidence of the non-resident shareholder's identity, financial capacity, audited financial statements, tax returns, remittance records and correspondence. Lack of detailed discussion in the assessment order did not prove absence of inquiry, and a permissible view taken after inquiry could not be revised merely because further inquiry was considered desirable. A direction for fresh examination required a clear finding of legal error supported by at least minimal independent inquiry. As no such error was established, the revisionary order was invalid and the direction to re-examine share capital was quashed. Case-Laws Income Tax Fri, 07 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797080