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Revision for inadequate inquiry under section 263 requires a showing that the Assessing Officer's inquiry was inadequate; a different revisional view alone does not satisfy Explanation 2(a). Reassessment initiated on specific information about alleged penny-stock share transactions involved queries and consideration of contract notes, brokerage and ledger records, and bank statements. Acceptance of short-term capital gains as genuine was therefore a plausible view. The reassessment order was not erroneous or prejudicial to Revenue interests, the revision was annulled, and the proposed-addition challenge became infructuous.
Revision for inadequate inquiry under section 263 requires a showing that the Assessing Officer's inquiry was inadequate; a different revisional view alone does not satisfy Explanation 2(a). Reassessment initiated on specific information about alleged penny-stock share transactions involved queries and consideration of contract notes, brokerage and ledger records, and bank statements. Acceptance of short-term capital gains as genuine was therefore a plausible view. The reassessment order was not erroneous or prejudicial to Revenue interests, the revision was annulled, and the proposed-addition challenge became infructuous.
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