Revisional Authority U/S 264 Of Income Tax Act Can Only Review Existing Orders, Cannot Issue Directions To Assessing Authority: Kerala HC

The Kerala High Court has ruled that revisional powers under Section 264 of the Income Tax Act are confined to existing orders and cannot issue directions to the Assessing Authority (AO). Section 264 allows the Principal Commissioner or Commissioner to revise any order prejudicial to the assessee. The court clarified that this power is limited to correcting or modifying an existing order based on records, but does not extend to directing the AO to conduct fresh inquiries or issue new directions. This ruling defines the scope of revisional jurisdiction, preventing it from becoming an investigatory power.