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    <title>2021 (6) TMI 752 - ITAT KOLKATA</title>
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    <description>Revision under section 263 is available only where the assessment order is both erroneous and prejudicial to the Revenue. An order is not erroneous when the Assessing Officer has made enquiries, called for particulars, examined supporting documents, and then adopted one permissible view. Here, specific queries were raised on share investments and short-term capital loss, and the assessee furnished contract notes, bank statements, and other material. The assessment was therefore made after due enquiry and application of mind, so the Principal Commissioner could not revise it merely for a different view on the adequacy of enquiry or on an unsupported assumption that the scrips were penny stocks. The revision was invalid and the revisional order was quashed.</description>
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      <description>Revision under section 263 is available only where the assessment order is both erroneous and prejudicial to the Revenue. An order is not erroneous when the Assessing Officer has made enquiries, called for particulars, examined supporting documents, and then adopted one permissible view. Here, specific queries were raised on share investments and short-term capital loss, and the assessee furnished contract notes, bank statements, and other material. The assessment was therefore made after due enquiry and application of mind, so the Principal Commissioner could not revise it merely for a different view on the adequacy of enquiry or on an unsupported assumption that the scrips were penny stocks. The revision was invalid and the revisional order was quashed.</description>
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