Shanti Prime Publication Pvt. Ltd.
Section 263 of the Income Tax Act, 1961 — Revision — Although the provisions of section 263 appear to be very wide more particularly after insertion of explanation (2), it cannot possibly mean that recourse to Section 263 would be available to the revisional authority on each and every inadequacy in the matter of enquiries; the Commissioner of Income Tax is expected to show that the view taken by the AO is wholly unsustainable in law before embarking upon exercise of revisional powers — Torrent Pharmaceuticals Ltd vs. Deputy Commissioner of Income tax [2018] 196 TTJ (Ahmedabad) 318