Section 263 Sustained

This ruling reinforces a critical distinction in tax jurisprudence:

“Inquiry” is not a procedural ritual, it must culminate in application of mind.

The ITAT held that where the Assessing Officer merely gathers information but fails to analyze, verify, or draw conclusions, the order falls squarely within Explanation 2(a) to Section 263.

The decision strengthens the Revenue’s ability to invoke revisionary powers in cases of passive or mechanical assessments, particularly under faceless regimes.