https://www.taxtmi.com/caselaws?id=799129 Revision jurisdiction requires an assessment order to be both erroneous and prejudicial to Revenue. Absence of enquiry into the actual use of borrowings and the possible capitalisation of related interest can justify fresh examination. Revision cannot, however, direct fishing or roving verification without identifying a specific error causing prejudice. Where the Assessing Officer has examined expenditure records, tax-deduction particulars, contractual materials and treaty applicability, a plausible view reached after enquiry cannot be replaced through revision. Accordingly, fresh examination is confined to the interest-capitalisation issue, while directions concerning tax deduction on payments to Government authorities, miscellaneous expenditure and service-provider charges are unsustainable. en-us Mon, 10 Aug 2026 00:00:00 +0530 Thu, 17 Sep 2026 07:52:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799129 Revision jurisdiction requires an assessment order to be both erroneous and prejudicial to Revenue. Absence of enquiry into the actual use of borrowings and the possible capitalisation of related interest can justify fresh examination. Revision cannot, however, direct fishing or roving verification without identifying a specific error causing prejudice. Where the Assessing Officer has examined expenditure records, tax-deduction particulars, contractual materials and treaty applicability, a plausible view reached after enquiry cannot be replaced through revision. Accordingly, fresh examination is confined to the interest-capitalisation issue, while directions concerning tax deduction on payments to Government authorities, miscellaneous expenditure and service-provider charges are unsustainable. Case-Laws Income Tax Mon, 10 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799129