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    <title>2023 (4) TMI 1111 - ITAT PUNE</title>
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    <description>Revision under section 263 was upheld because the assessment had been completed without adequate enquiry and verification into disputed claims and credits, making it erroneous and prejudicial to the interests of the Revenue under Explanation 2. The fact that the revision proposal originated from field authorities did not invalidate the revisional jurisdiction, as there was no statutory bar and the Principal Commissioner was found to have applied independent consideration. Pending appeal against the assessment did not bar revision under Explanation 1(c) because the relevant issue had not already been considered and decided in appeal. The direction to proceed under section 144 caused no prejudice, since the assessment had already been framed on a best-judgment basis after the assessee failed to substantiate its claims.</description>
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      <title>2023 (4) TMI 1111 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=437085</link>
      <description>Revision under section 263 was upheld because the assessment had been completed without adequate enquiry and verification into disputed claims and credits, making it erroneous and prejudicial to the interests of the Revenue under Explanation 2. The fact that the revision proposal originated from field authorities did not invalidate the revisional jurisdiction, as there was no statutory bar and the Principal Commissioner was found to have applied independent consideration. Pending appeal against the assessment did not bar revision under Explanation 1(c) because the relevant issue had not already been considered and decided in appeal. The direction to proceed under section 144 caused no prejudice, since the assessment had already been framed on a best-judgment basis after the assessee failed to substantiate its claims.</description>
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      <pubDate>Tue, 25 Apr 2023 00:00:00 +0530</pubDate>
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