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Revision u/s 263 - Exemption u/s 11 - If the order of the AO does not disclose the basis of his conclusion, then jurisdiction u/s 263 of the Act can be ignored. Therefore, the CIT was justified in directing the AO to examine the allowability of these items of expenditure. The assessee is always at liberty to show as to how the material found in the survey was not sufficient to make any additions in the hands of the assessee. We, therefore, confirm the order of the CIT. - AT
Revision u/s 263 - Exemption u/s 11 - If the order of the AO does not disclose the basis of his conclusion, then jurisdiction u/s 263 of the Act can be ignored. Therefore, the CIT was justified in directing the AO to examine the allowability of these items of expenditure. The assessee is always at liberty to show as to how the material found in the survey was not sufficient to make any additions in the hands of the assessee. We, therefore, confirm the order of the CIT. - AT
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