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    <title>2022 (12) TMI 1280 - ITAT MUMBAI</title>
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    <description>Revision under section 263 was held unjustified where the Assessing Officer had examined the assessee&#039;s section 54F claim, raised queries on the purchase of the new property through an unregistered document, and accepted the explanation after enquiry. On those facts, the assessment could not be treated as lacking inquiry or application of mind. The Tribunal also noted that registration of the conveyance deed was not indispensable for section 54F on its earlier view, and that the Commissioner&#039;s different opinion did not by itself permit revision. The revision order was quashed.</description>
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      <description>Revision under section 263 was held unjustified where the Assessing Officer had examined the assessee&#039;s section 54F claim, raised queries on the purchase of the new property through an unregistered document, and accepted the explanation after enquiry. On those facts, the assessment could not be treated as lacking inquiry or application of mind. The Tribunal also noted that registration of the conveyance deed was not indispensable for section 54F on its earlier view, and that the Commissioner&#039;s different opinion did not by itself permit revision. The revision order was quashed.</description>
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