Exercise of revisionary jurisdiction under section 263 of Income Tax Act, 1961

RELEVANT PARAGRAPHS: 6. We have considered the facts of the case and rival submissions. The principles of law emerging from various decisions cited by the rival parties can be summarized as under : (i) two pre-conditions have been prescribed for invoking jurisdiction under section 263, namely (a) the order passed by the Assessing Officer should be erroneous; and (b) it should be prejudicial to the interests of the revenue; (ii) where proper enquiries have been conducted by the Assessing Officer and he has followed the principles of natural justice, the order passed by him cannot be said to be ...