Constructive receipt of interest through equity conversion supports revision where the assessment lacked necessary inquiry.

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....Revisionary jurisdiction applies where a reassessment accepts non-taxability of accumulated interest without necessary inquiry or application of governing provisions, rendering it erroneous and prejudicial to Revenue interests and permitting fresh determination. Premature conversion of zero-coupon debentures into equity shares of ascertainable value can constitute constructive receipt of accumulated interest even under cash-basis accounting. Claiming tax-deducted-at-source credit for that interest is inconsistent with denying the underlying income. The capital-gains exclusion for conversion does not exempt embedded interest from taxation; once taxed, the interest forms part of the shares' cost basis, preventing double taxation on sale.....