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    <title>2015 (7) TMI 1351 - ITAT MUMBAI</title>
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    <description>Revision under section 263 of the Income-tax Act was not justified where the Assessing Officer had already examined prior-year expenses, set-off of brought forward losses and the disputed claim, and had taken a view after verification. The Commissioner&#039;s notice overlapped with matters already considered in assessment, and section 263 could be invoked only if the order was both erroneous and prejudicial to the Revenue. A different opinion or lack of elaborate reasoning was insufficient, and a mere possible loss of revenue did not meet the statutory test. The revisionary order was therefore unsustainable.</description>
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      <description>Revision under section 263 of the Income-tax Act was not justified where the Assessing Officer had already examined prior-year expenses, set-off of brought forward losses and the disputed claim, and had taken a view after verification. The Commissioner&#039;s notice overlapped with matters already considered in assessment, and section 263 could be invoked only if the order was both erroneous and prejudicial to the Revenue. A different opinion or lack of elaborate reasoning was insufficient, and a mere possible loss of revenue did not meet the statutory test. The revisionary order was therefore unsustainable.</description>
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