https://www.taxtmi.com/highlights?id=104312 Revisionary jurisdiction for inadequate inquiry into TDS on commission and brokerage expenditure arises where the Assessing Officer merely calls for TDS details without examining a material mismatch between financial-statement expenditure and TDS reporting. A substantial increase in expenditure and a claim that amounts retained by franchisees constituted discounts rather than commission require specific examination of contractual arrangements, accounting treatment and TDS liability. Failure to conduct that inquiry may render an assessment erroneous and prejudicial to Revenue interests, rather than reflecting a prohibited change of opinion. The revisionary order was sustained, leaving the expenditure's nature and tax consequences for fresh assessment after giving the assessee an opportunity to respond. en-us Tue, 29 Sep 2026 08:34:54 +0530 Tue, 29 Sep 2026 08:34:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=104312 Revisionary jurisdiction for inadequate inquiry into TDS on commission and brokerage expenditure arises where the Assessing Officer merely calls for TDS details without examining a material mismatch between financial-statement expenditure and TDS reporting. A substantial increase in expenditure and a claim that amounts retained by franchisees constituted discounts rather than commission require specific examination of contractual arrangements, accounting treatment and TDS liability. Failure to conduct that inquiry may render an assessment erroneous and prejudicial to Revenue interests, rather than reflecting a prohibited change of opinion. The revisionary order was sustained, leaving the expenditure's nature and tax consequences for fresh assessment after giving the assessee an opportunity to respond. Highlights Income Tax Tue, 29 Sep 2026 08:34:54 +0530 https://www.taxtmi.com/highlights?id=104312