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The ITAT held that revision proceedings under Section 263 cannot be sustained where there is no total lack of enquiry by the AO, only inadequacy. The AO's investigation was confined to rental income, which was the principal issue, and thus not a complete absence of enquiry. An error or omission regarding the claim of interest under Section 24(a) amounts to inadequate enquiry, requiring the Pr. CIT to conduct independent inquiry before invoking revision powers. The Pr. CIT failed to demonstrate any inquiry or collect material to justify the revision of eight assessment orders, acting in a hurried and mechanical manner without proper application of mind. Consequently, the ITAT set aside the Pr. CIT's revision orders as legally untenable and allowed the assessee's appeal.
The ITAT held that revision proceedings under Section 263 cannot be sustained where there is no total lack of enquiry by the AO, only inadequacy. The AO's investigation was confined to rental income, which was the principal issue, and thus not a complete absence of enquiry. An error or omission regarding the claim of interest under Section 24(a) amounts to inadequate enquiry, requiring the Pr. CIT to conduct independent inquiry before invoking revision powers. The Pr. CIT failed to demonstrate any inquiry or collect material to justify the revision of eight assessment orders, acting in a hurried and mechanical manner without proper application of mind. Consequently, the ITAT set aside the Pr. CIT's revision orders as legally untenable and allowed the assessee's appeal.
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