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    <title>2023 (11) TMI 793 - ITAT CHENNAI</title>
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    <description>Revision under section 263 could not be sustained because the record showed that the assessment had already examined the exemption claim under sections 11 and 12, including receipts, application of income and accumulation. The revisionary authority relied on Ahmedabad Urban Development Authority and sought further enquiry into section 2(15), but did not independently show how the proviso was breached or how the Assessing Officer&#039;s order was both erroneous and prejudicial to the Revenue. A bare direction for fresh enquiry, without a specific finding of error on the existing record, was insufficient. The revision order was therefore quashed and the assessee&#039;s appeal succeeded.</description>
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      <title>2023 (11) TMI 793 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=445902</link>
      <description>Revision under section 263 could not be sustained because the record showed that the assessment had already examined the exemption claim under sections 11 and 12, including receipts, application of income and accumulation. The revisionary authority relied on Ahmedabad Urban Development Authority and sought further enquiry into section 2(15), but did not independently show how the proviso was breached or how the Assessing Officer&#039;s order was both erroneous and prejudicial to the Revenue. A bare direction for fresh enquiry, without a specific finding of error on the existing record, was insufficient. The revision order was therefore quashed and the assessee&#039;s appeal succeeded.</description>
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