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2013 (12) TMI 250 - HC - Income TaxValidity of Revision u/s 263 - power of CIT - Held that:- The scope of interference under Section 263 is not to set aside merely unfavourable orders and bring to tax some more money to the treasury nor is the section meant to get at sheer escapement of revenue which is taken care of by other provisions in the Act - The prejudice that is contemplated under Sec. 263 is prejudice to the income tax administration as a whole. Section 263 is to be invoked not as a jurisdictional corrective or as a review of a subordinate's order in exercise of the supervisory power but it is to be invoked and employed only for the purpose of setting right distortions and prejudices to the Revenue which is a unique conception which has to be understood in the context of and in the interest of revenue administration - Such a power cannot be equated to, or regarded as approaching in any way the appellate jurisdiction of even the ordinary revisional jurisdiction conferred on the Commissioner under Section 264 - The assessee-Trust cannot be said to have made the payment of estate duty on behalf of the settler - Decided against Revenue.
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