S. 263 Is Not A Second Opinion — It’s For Real Errors: ITAT

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S. 263 Is Not A Second Opinion — It’s For Real Errors: ITAT

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Published on

18/02/2026

By Mariya Paliwala

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The Delhi Bench of Income Tax Appellate Tribunal (ITAT) held that revision under section 263 of the Income Tax Act cannot be sustained where the Assessing Officer has already made enquiries, examined the material on record, and taken a plausible view—because Section 263 is not a review or “second opinion” jurisdiction. The bench of Mahavir…

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Mariya Paliwala https://www.jurishour.in/

Mariya is the Senior Editor at Juris Hour. She has 7+ years of experience on covering tax litigation stories from the Supreme Court, High Courts and various tribunals including CESTAT, ITAT, NCLAT, NCLT, etc. Mariya graduated from MLSU Law College, Udaipur (Raj.) with B.A.LL.B. and also holds an LL.M. She started her career as a freelance tax reporter in the leading online legal news companies.

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S. 263 Is Not A Second Opinion — It’s For Real Errors: ITAT

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