Revision — S. 263 — Lack of enquiry and inadequate enquiry — Explanation 2 to section 263 of the Act invoked for verification of documentary evidence regarding the claim of utilization out of accumulations made u/s. 11(2) of the Act — No prior show cause notice issued for invocation of Explanation to section 263 —Assessee furnished details during the assessment proceedings — Enquiry was made and possible view taken — Commissioner cannot re-open the matter u/s. 263 because there was another view or because the Commissioner desires further enquiry.

15. CIT(E) v. Impact Foundation (India)

2026 (5) TMI 331 (Bom.)

A. Y. 2016-17: Date of order 04/05/2026

S. 263 of ITA 1961

Revision — S. 263 — Lack of enquiry and inadequate enquiry — Explanation 2 to section 263 of the Act invoked for verification of documentary evidence regarding the claim of utilization out of accumulations made u/s. 11(2) of the Act — No prior show cause notice issued for invocation of Explanation to section 263 —Assessee furnished details during the assessment proceedings — Enquiry was made and possible view taken — Commissioner cannot re-open the matter u/s. 263 because there was another view or because the Commissioner desires further enquiry.

The Assessee is a non-profit company registered u/s. 25 of the Companies Act, 1956 and registered u/s. 12AA of the Income-tax Act, 1961 and is formed for helping organisations to improve implementation of programs which help women and children in education, health and livelihoods. The Assessee filed its return of income declaring total income at Rs. NIL. The Assessee, being registered u/s. 12AA, also claimed benefit u/s. 80G and claimed exemption u/s. 11 of the Act. The Assessee’s case was selected