https://www.taxtmi.com/caselaws?id=473016 Revisionary jurisdiction under section 263 requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. Verification of fresh unsecured loans through confirmations, tax returns, computations, balance sheets, bank statements and supporting agricultural-land evidence constituted an inquiry. Comparing loan amounts only with lenders' taxable income, without considering exempt income, capital and other funds, did not establish absence of inquiry. A supervisory view that further verification was desirable cannot equate an allegedly inadequate inquiry with no inquiry. On these facts, the assessment order was not erroneous and prejudicial, rendering the section 263 revision invalid. en-us Thu, 24 Apr 2025 00:00:00 +0530 Sat, 31 Oct 2026 17:44:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=473016 Revisionary jurisdiction under section 263 requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. Verification of fresh unsecured loans through confirmations, tax returns, computations, balance sheets, bank statements and supporting agricultural-land evidence constituted an inquiry. Comparing loan amounts only with lenders' taxable income, without considering exempt income, capital and other funds, did not establish absence of inquiry. A supervisory view that further verification was desirable cannot equate an allegedly inadequate inquiry with no inquiry. On these facts, the assessment order was not erroneous and prejudicial, rendering the section 263 revision invalid. Case-Laws Income Tax Thu, 24 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=473016