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Revision of block assessment under section 263 could not revisit additions concerning claimed unaccounted expenditure, asset investments and petrol-pump income after those additions had been adjudicated in appellate proceedings and the Tribunal's decision had attained finality following dismissal of Revenue appeals. Revisionary proceedings on those matters were therefore set aside. Regarding tanker acquisition and operating income, concurrent factual findings after record verification established no material showing unaccounted income. With no legal infirmity in those findings, deletion of the tanker-related addition was sustained and the Revenue's appeals were dismissed.
Revision of block assessment under section 263 could not revisit additions concerning claimed unaccounted expenditure, asset investments and petrol-pump income after those additions had been adjudicated in appellate proceedings and the Tribunal's decision had attained finality following dismissal of Revenue appeals. Revisionary proceedings on those matters were therefore set aside. Regarding tanker acquisition and operating income, concurrent factual findings after record verification established no material showing unaccounted income. With no legal infirmity in those findings, deletion of the tanker-related addition was sustained and the Revenue's appeals were dismissed.
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