Assessee's custodial role exempts income from tax, CIT(E)'s revisional order quashed.

The assessee, acting in a custodial role as an agent for the State Government, was exempted from tax on income, as ownership of the collected funds remained with the government. The Revenue's argument that the activities were commercial was rejected, referencing a Supreme Court decision. The CIT(E)'s directive to verify Section 11 exemption was deemed unjustified since the ITAT had already examined the nature of receipts, and no new income sources were identified. The CIT(E)'s revisional order under Section 263 was quashed, and the assessee's appeal was allowed, as Section 263 cannot be invoked merely on a change of opinion. .....

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