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    <title>2012 (11) TMI 1071 - RAJASTHAN HIGH COURT</title>
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    <description>The High Court dismissed the Revenue&#039;s appeal, affirming the Tribunal&#039;s decision that the CIT was not justified in invoking revisional jurisdiction under Section 263 of the IT Act. The Court held that the essential conditions for invoking Section 263 were not met, and the Tribunal&#039;s findings were based on facts and legal precedents. The assessment order had already merged with the appellate order, and the CIT could not revise it merely due to a difference of opinion or perceived insufficiency of enquiry by the AO.</description>
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      <description>The High Court dismissed the Revenue&#039;s appeal, affirming the Tribunal&#039;s decision that the CIT was not justified in invoking revisional jurisdiction under Section 263 of the IT Act. The Court held that the essential conditions for invoking Section 263 were not met, and the Tribunal&#039;s findings were based on facts and legal precedents. The assessment order had already merged with the appellate order, and the CIT could not revise it merely due to a difference of opinion or perceived insufficiency of enquiry by the AO.</description>
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