https://www.taxtmi.com/caselaws?id=798473 Revision under section 263 requires an assessment order to be both erroneous and prejudicial to Revenue. Deduction under section 80P(2)(d) on interest from a Regional Rural Bank had been specifically examined and allowed after inquiry, following jurisdictional High Court precedent treating a Regional Rural Bank as a co-operative society through the statutory deeming fiction in the Regional Rural Banks Act, 1976. Section 80P(4) did not displace that precedent. A later contrary coordinate-bench view could neither retrospectively make the assessment erroneous nor override binding High Court authority. Explanation 2 to section 263 did not apply because there was no lack of inquiry; consequently, revision was unsustainable. en-us Wed, 12 Aug 2026 00:00:00 +0530 Tue, 08 Sep 2026 08:42:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798473 Revision under section 263 requires an assessment order to be both erroneous and prejudicial to Revenue. Deduction under section 80P(2)(d) on interest from a Regional Rural Bank had been specifically examined and allowed after inquiry, following jurisdictional High Court precedent treating a Regional Rural Bank as a co-operative society through the statutory deeming fiction in the Regional Rural Banks Act, 1976. Section 80P(4) did not displace that precedent. A later contrary coordinate-bench view could neither retrospectively make the assessment erroneous nor override binding High Court authority. Explanation 2 to section 263 did not apply because there was no lack of inquiry; consequently, revision was unsustainable. Case-Laws Income Tax Wed, 12 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798473