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    <title>2021 (11) TMI 33 - ITAT MUMBAI</title>
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    <description>Revision under section 263 was held unsustainable because the Assessing Officer had made enquiries on the charity and educational expenditure, examined the supporting material, and adopted a plausible view in the assessment. The same result followed on the capital gains issue: the transfer-related receipts were explained as advances, the claimed transfer of rights depended on prior sanction under the Maharashtra Public Trusts Act, and the possession relied upon was not possession in part performance of the relevant contract. As the assessment was made after enquiry and on a permissible view, the twin conditions for revision were not met and the assessee&#039;s appeal succeeded.</description>
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      <title>2021 (11) TMI 33 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=414252</link>
      <description>Revision under section 263 was held unsustainable because the Assessing Officer had made enquiries on the charity and educational expenditure, examined the supporting material, and adopted a plausible view in the assessment. The same result followed on the capital gains issue: the transfer-related receipts were explained as advances, the claimed transfer of rights depended on prior sanction under the Maharashtra Public Trusts Act, and the possession relied upon was not possession in part performance of the relevant contract. As the assessment was made after enquiry and on a permissible view, the twin conditions for revision were not met and the assessee&#039;s appeal succeeded.</description>
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