https://www.taxtmi.com/caselaws?id=800257 Section 264 revision requires the Commissioner to examine an assessee's grounds and supporting material on merits, even where the assessee did not participate in reassessment proceedings. The Commissioner may call for records and make or direct inquiries, but must pass an order not prejudicial to the assessee. Non-compliance with reassessment notices does not remove the duty to give reasoned consideration to the revision claim. Rejecting revision through a bare assertion that the assessment order is well reasoned, without addressing submissions, is a non-speaking and unsustainable exercise of revisionary jurisdiction. en-us Tue, 29 Sep 2026 00:00:00 +0530 Sat, 03 Oct 2026 09:32:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800257 Section 264 revision requires the Commissioner to examine an assessee's grounds and supporting material on merits, even where the assessee did not participate in reassessment proceedings. The Commissioner may call for records and make or direct inquiries, but must pass an order not prejudicial to the assessee. Non-compliance with reassessment notices does not remove the duty to give reasoned consideration to the revision claim. Rejecting revision through a bare assertion that the assessment order is well reasoned, without addressing submissions, is a non-speaking and unsustainable exercise of revisionary jurisdiction. Case-Laws Income Tax Tue, 29 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800257