https://www.taxtmi.com/caselaws?id=472583 Section 263 revisional jurisdiction requires the revisional authority to examine the record and independently form its opinion. Reliance solely on the Assessing Officer's proposal constitutes borrowed satisfaction and lacks independent application of mind, rendering revision invalid. Where loan transactions have been examined through summons and lender responses, an alleged deficiency is inadequate enquiry rather than lack of enquiry; it does not justify revision on that basis. Explanation 2 cannot support a revision order unless its proposed application was put to the assessee in the show-cause notice. The revision order was therefore quashed. en-us Fri, 24 Feb 2023 00:00:00 +0530 Fri, 16 Oct 2026 18:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472583 Section 263 revisional jurisdiction requires the revisional authority to examine the record and independently form its opinion. Reliance solely on the Assessing Officer's proposal constitutes borrowed satisfaction and lacks independent application of mind, rendering revision invalid. Where loan transactions have been examined through summons and lender responses, an alleged deficiency is inadequate enquiry rather than lack of enquiry; it does not justify revision on that basis. Explanation 2 cannot support a revision order unless its proposed application was put to the assessee in the show-cause notice. The revision order was therefore quashed. Case-Laws Income Tax Fri, 24 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472583