2025 (3) TMI 882

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..... Raj Bahadur Yadav, AOR, Mr. Karan Lahiri, Adv., Mr. Santosh Kumar, Adv., Mr. Piyush Beriwal, Adv. And Mr. Udit Dedhiya, Adv. For the Respondent(s) : None ORDER Delay condoned. This special leave petition is misconceived and is completely contrary to the law pertaining to Section 263 of the Income Tax Act, 1961. "1961 Act", for short. The notice under Section 148 of the 1961 Act referred to t .....

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..... assessment proceedings. Therefore, to exercise jurisdiction under Section 263 of the 1961 Act, the Commissioner of Income Tax should have examined the merits and only on reaching a finding that the re-assessment order was erroneous and prejudicial to the interest of the Revenue made an addition. This is not a case of 'no inquiry and verification', but as made out by the Revenue, a case of wrong c .....

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