Impact Foundation Bombay High Court Upholds ITAT Order Quashing Section 263 Revision Against Charitable Institution

The Bombay High Court dismissed the Revenue’s appeal and upheld the Income Tax Appellate Tribunal’s order quashing revisionary proceedings initiated under Section 263 against Impact Foundation (India). 

The Court held that once the Assessing Officer had conducted inquiries, examined material on record, and adopted a plausible view, the Commissioner could not invoke revisionary jurisdiction merely because deeper or further inquiry was possible. 

The judgment also reiterates that Section 263 cannot be used to initiate fishing or roving inquiries and emphasizes the distinction between “lack of inquiry” and “inadequate inquiry.”