AI OCR 
TaxTMI 
TaxTMI 
TaxTMI 
Revision of orders prejudicial to revenue - Section 263
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....passed by the AO or TPO is considered "erroneous in so far as it is prejudicial to the interests of the revenue." Opportunity of Being Heard and Inquiry Section 263(1) mandates that the assessee must be given an opportunity of being heard before any revisionary order is passed. This is a fundamental principle of natural justice. * Inquiry: The Commissioner may make or cause to be made any inqu....
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....uding orders passed on the basis of directions from higher authorities and orders u/s 92CA. it is declared that the Principal Commissioner or commissioner have also been vested with power of revision u/s 263,-An order passed the Assessing Officer or the Transfer Pricing Officer, as the case may be, shall include- * an order of assessment made by the Assistant Commissioner or Deputy Commissione....
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....that an order passed by the Assessing Officer shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal Commissioner or Commissioner, - * the order is passed without making inquiries or verification which should have been made; * the order is passed allowing any relief without inquiring into the claim; * the order has ....
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.... the purposes of sub-section (2), the time taken in giving an opportunity to the assessee to be reheard under the proviso to section 129 and [any period during which any proceeding under this section is stayed by an order or injunction of any court the period commencing on the date on which stay on any proceeding under this section was granted by an order or injunction of any court and ending....