https://www.taxtmi.com/caselaws?id=798086 For assessment year 2022-23, Explanation 4(ii) to Section 11(1) treated repayment of loans from current-year income as application of income. Qualifying restrictions introduced from 1 April 2023 applied prospectively and could not govern the earlier year. Section 263 revision was therefore unavailable where the assessment adopted this legally plausible interpretation. Limited scrutiny had specifically examined the repayment claim, obtained relevant particulars and supporting material, and accepted the explanation. The absence of detailed reasoning in the assessment order did not establish lack of enquiry; revision cannot rest solely on a view that more extensive enquiry was desirable. The original assessment consequently stood restored. en-us Thu, 06 Aug 2026 00:00:00 +0530 Wed, 02 Sep 2026 08:30:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798086 For assessment year 2022-23, Explanation 4(ii) to Section 11(1) treated repayment of loans from current-year income as application of income. Qualifying restrictions introduced from 1 April 2023 applied prospectively and could not govern the earlier year. Section 263 revision was therefore unavailable where the assessment adopted this legally plausible interpretation. Limited scrutiny had specifically examined the repayment claim, obtained relevant particulars and supporting material, and accepted the explanation. The absence of detailed reasoning in the assessment order did not establish lack of enquiry; revision cannot rest solely on a view that more extensive enquiry was desirable. The original assessment consequently stood restored. Case-Laws Income Tax Thu, 06 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798086