https://www.taxtmi.com/caselaws?id=799665 Revisionary jurisdiction under Section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests. Explanation 2(a) covers a failure to conduct enquiries or verification that ought to have been made, not merely an allegedly inadequate enquiry. Examination of seized records, statements, supporting documents, digital data and third-party responses, together with summons and notices, demonstrated substantive verification. Where the Assessing Officer evaluates that material, makes additions and adopts a view, further investigation into the same material cannot replace an independent finding that the assessment is erroneous or legally unsustainable. The revision order was invalid and the assessment was restored. en-us Wed, 16 Sep 2026 00:00:00 +0530 Fri, 25 Sep 2026 08:16:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799665 Revisionary jurisdiction under Section 263 requires an assessment order to be both erroneous and prejudicial to Revenue interests. Explanation 2(a) covers a failure to conduct enquiries or verification that ought to have been made, not merely an allegedly inadequate enquiry. Examination of seized records, statements, supporting documents, digital data and third-party responses, together with summons and notices, demonstrated substantive verification. Where the Assessing Officer evaluates that material, makes additions and adopts a view, further investigation into the same material cannot replace an independent finding that the assessment is erroneous or legally unsustainable. The revision order was invalid and the assessment was restored. Case-Laws Income Tax Wed, 16 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799665