#Prejudicial to Revenue

The ITAT Kolkata has ruled that invoking Section 263 to revise a previously scrutinized assessment is impermissible unless the revenue demonstrates actual prejudice, not just a technical error. This clarifies that scrutiny under Section 143(3) does not waive the twin-condition test, protecting taxpayers from arbitrary revisionary orders and reinforcing procedural fairness in income tax administration.

ITAT Bangalore holds that Section 263 cannot be invoked merely because the Commissioner disagrees with a plausible view taken by the AO on interest income eligibility under Section 80P.