In Brief
The Revenue (Income Tax Commissioner) challenged the High Court's order dismissing its revision of an assessment under Section 263 of the Income Tax Act, 1961. The assessee, Amitabh Bachchan, claimed additional expenses in a revised return but later withdrew the claim. The Supreme Court held that the Commissioner could exercise revisional powers on grounds beyond a show cause notice so long as the assessee received a genuine opportunity to be heard. The Court ruled that withdrawal of an expense claim does not preclude further investigation into whether expenses were actually incurred. The Commissioner's satisfaction that the assessment was erroneous and prejudicial to revenue justified the revision order. The appeal was allowed and the Commissioner's revisional order was restored.
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