https://www.taxtmi.com/caselaws?id=798214 Revision under section 263 requires both an erroneous assessment order and prejudice to Revenue. Interest reimbursed on a back-to-back basis to an intermediary for payment to ultimate debenture holders, where the intermediary retains no income beyond its taxed margin, does not create tax-deduction liability under section 194A or disallowance under section 40(a)(ia). Revisionary action also lacks basis where profit-before-tax and ICDS explanations, supporting material, and relevant records were already before the assessment authority; further verification without demonstrated error and prejudice is a roving enquiry. On these principles, the original assessment remains operative. en-us Mon, 31 Aug 2026 00:00:00 +0530 Thu, 03 Sep 2026 08:20:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798214 Revision under section 263 requires both an erroneous assessment order and prejudice to Revenue. Interest reimbursed on a back-to-back basis to an intermediary for payment to ultimate debenture holders, where the intermediary retains no income beyond its taxed margin, does not create tax-deduction liability under section 194A or disallowance under section 40(a)(ia). Revisionary action also lacks basis where profit-before-tax and ICDS explanations, supporting material, and relevant records were already before the assessment authority; further verification without demonstrated error and prejudice is a roving enquiry. On these principles, the original assessment remains operative. Case-Laws Income Tax Mon, 31 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798214