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    <title>2021 (10) TMI 1144 - ITAT SURAT</title>
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    <description>Section 263 revision requires the assessment order to be both erroneous and prejudicial to the Revenue. Where the Assessing Officer issues a detailed questionnaire, examines explanations and supporting records, and adopts a plausible view on the assessee&#039;s IDS disclosure, returned income, expenses, cash transactions, loans and penalty non-initiation, revision cannot be justified merely because the revisional authority prefers further enquiry. The record also did not show that the IDS declaration had been revoked for misrepresentation or that acceptance of the assessee&#039;s explanation was unsustainable in law. On this reasoning, the revisionary action was held unsustainable and the assessment revision was set aside.</description>
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    <pubDate>Thu, 21 Oct 2021 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=414092</link>
      <description>Section 263 revision requires the assessment order to be both erroneous and prejudicial to the Revenue. Where the Assessing Officer issues a detailed questionnaire, examines explanations and supporting records, and adopts a plausible view on the assessee&#039;s IDS disclosure, returned income, expenses, cash transactions, loans and penalty non-initiation, revision cannot be justified merely because the revisional authority prefers further enquiry. The record also did not show that the IDS declaration had been revoked for misrepresentation or that acceptance of the assessee&#039;s explanation was unsustainable in law. On this reasoning, the revisionary action was held unsustainable and the assessment revision was set aside.</description>
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