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    <title>2023 (1) TMI 203 - ITAT CHENNAI</title>
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    <description>A revision under section 263 was held justified where the Assessing Officer accepted foreign exchange and fair value adjustments without proper enquiry into their tax impact and revenue recognition consequences. The record showed only a preliminary query and reply, so the assessment order was treated as passed without adequate application of mind and as contrary to binding precedent. Withdrawal of the section 43AA reference did not require a fresh notice because the core revisional issue remained the tax treatment of the adjustments and the assessee had a fair opportunity to answer the substance of the objection. The challenge to the revision therefore failed.</description>
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      <title>2023 (1) TMI 203 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=432456</link>
      <description>A revision under section 263 was held justified where the Assessing Officer accepted foreign exchange and fair value adjustments without proper enquiry into their tax impact and revenue recognition consequences. The record showed only a preliminary query and reply, so the assessment order was treated as passed without adequate application of mind and as contrary to binding precedent. Withdrawal of the section 43AA reference did not require a fresh notice because the core revisional issue remained the tax treatment of the adjustments and the assessee had a fair opportunity to answer the substance of the objection. The challenge to the revision therefore failed.</description>
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