https://www.taxtmi.com/caselaws?id=472273 Section 263 revision requires the revisional authority to independently examine the assessment record and identify an assessment that is both erroneous and prejudicial to Revenue. Revision is not invalid merely because the Assessing Officer may have recommended action where the show-cause notice and revision order demonstrate independent application of mind. Reassessment-jurisdiction objections, including alleged borrowed satisfaction and defective disposal of reopening objections, cannot be used as a collateral challenge in revision proceedings; procedural defects may be curable. Failure to meaningfully examine seized material indicating accommodation-entry share capital, including failure to confront material and verify investment genuineness, can justify revision and a fresh assessment. en-us Wed, 07 Sep 2022 00:00:00 +0530 Tue, 06 Oct 2026 14:52:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472273 Section 263 revision requires the revisional authority to independently examine the assessment record and identify an assessment that is both erroneous and prejudicial to Revenue. Revision is not invalid merely because the Assessing Officer may have recommended action where the show-cause notice and revision order demonstrate independent application of mind. Reassessment-jurisdiction objections, including alleged borrowed satisfaction and defective disposal of reopening objections, cannot be used as a collateral challenge in revision proceedings; procedural defects may be curable. Failure to meaningfully examine seized material indicating accommodation-entry share capital, including failure to confront material and verify investment genuineness, can justify revision and a fresh assessment. Case-Laws Income Tax Wed, 07 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472273