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    <title>2024 (11) TMI 1325 - ALLAHABAD HIGH COURT</title>
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    <description>The Allahabad HC dismissed the department&#039;s appeal against ITAT&#039;s order setting aside a revision under section 263. The AO had not conducted proper enquiry regarding cash deposits during demonetization, scrap sales, and non-submission of audit reports. The HC held that the department only challenged ITAT&#039;s fact-finding, which does not raise substantial questions of law unless findings are perverse. The court found ITAT&#039;s detailed factual examination was reasonable and not perverse, as perversity requires findings without evidence or those no prudent person could reach. The appeal was dismissed as no substantial question of law arose from the factual determination.</description>
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    <pubDate>Thu, 21 Nov 2024 00:00:00 +0530</pubDate>
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      <title>2024 (11) TMI 1325 - ALLAHABAD HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=762339</link>
      <description>The Allahabad HC dismissed the department&#039;s appeal against ITAT&#039;s order setting aside a revision under section 263. The AO had not conducted proper enquiry regarding cash deposits during demonetization, scrap sales, and non-submission of audit reports. The HC held that the department only challenged ITAT&#039;s fact-finding, which does not raise substantial questions of law unless findings are perverse. The court found ITAT&#039;s detailed factual examination was reasonable and not perverse, as perversity requires findings without evidence or those no prudent person could reach. The appeal was dismissed as no substantial question of law arose from the factual determination.</description>
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