Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments.

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....Revision proceedings require the designated statutory authority to issue the notice in the correct official capacity. A Chief Commissioner issuing a notice as Principal Commissioner, without an express Board order authorising exercise of that function, lacks jurisdiction and invalidates the resulting revision. Revision for notional annual letting value of professionally used properties also cannot rest on a change of opinion where the Assessing Officer examined ownership, use and house-property treatment and adopted a plausible view. Explanation 2 to section 263 does not apply where genuine inquiry and verification occurred. Properties transferred by gift are not assessable in the transferor's hands. The revisional order was quashed.....