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    <title>2016 (3) TMI 548 - ITAT AHMEDABAD</title>
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    <description>Revision under section 263 was held unsustainable where the Assessing Officer had issued notices, called for details and examined the relevant material, because the Commissioner cannot revise merely for alleged inadequacy of discussion or a different view on the same record. The alleged share-transaction capital gain was also found outside Indian taxability under the Sri Lanka DTAA, so prejudice to the Revenue was not established. On the rental and related expenditure issue, the assessee had disclosed the particulars and the assessment was completed after inquiry; section 263 could not be used to substitute the Commissioner&#039;s opinion for a plausible assessment view. The revisional orders were quashed.</description>
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      <description>Revision under section 263 was held unsustainable where the Assessing Officer had issued notices, called for details and examined the relevant material, because the Commissioner cannot revise merely for alleged inadequacy of discussion or a different view on the same record. The alleged share-transaction capital gain was also found outside Indian taxability under the Sri Lanka DTAA, so prejudice to the Revenue was not established. On the rental and related expenditure issue, the assessee had disclosed the particulars and the assessment was completed after inquiry; section 263 could not be used to substitute the Commissioner&#039;s opinion for a plausible assessment view. The revisional orders were quashed.</description>
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