https://www.taxtmi.com/caselaws?id=797938 Revision under Section 263 applies where an assessment order is both erroneous and prejudicial to Revenue interests. Treating a cash payment as undisclosed investment without identifying and applying the governing charging provision and special tax rate indicates non-application of mind and can cause loss of tax lawfully payable. Applying an inapplicable penalty provision instead of the provision governing deemed undisclosed income similarly supports revision, as it may undermine consequential penalty proceedings. The revisionary authority may direct fresh inquiry and reassessment under the correct taxation and penalty provisions. en-us Wed, 12 Aug 2026 00:00:00 +0530 Mon, 31 Aug 2026 08:28:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797938 Revision under Section 263 applies where an assessment order is both erroneous and prejudicial to Revenue interests. Treating a cash payment as undisclosed investment without identifying and applying the governing charging provision and special tax rate indicates non-application of mind and can cause loss of tax lawfully payable. Applying an inapplicable penalty provision instead of the provision governing deemed undisclosed income similarly supports revision, as it may undermine consequential penalty proceedings. The revisionary authority may direct fresh inquiry and reassessment under the correct taxation and penalty provisions. Case-Laws Income Tax Wed, 12 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797938