Humane Section 264 revision requires enquiry-based scrutiny, not faceless dismissal of exemption claims and supporting records.
Section 264 revision requires the Commissioner to exercise revisional powers through an enquiry-based and humane approach, particularly where the assessee claims exemption and has placed prima facie supporting material on record. The revisional authority is not a passive forum of document collection; it must call for records, conduct or cause further enquiry where necessary, and then pass an order that is not prejudicial to the assessee. Faceless handling of the revision, without meaningful verification or clarification, was treated as falling short of the statutory standard. (AI Summary)