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    <title>2024 (12) TMI 906 - ITAT CHENNAI</title>
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    <description>The ITAT Chennai quashed the CIT&#039;s revision order under section 263. The CIT argued that the AO failed to properly examine incriminating search material regarding the assessee&#039;s money-lending business and outstanding debtors of Rs. 35 crores. However, the ITAT found that the AO had adequately inquired into the investment sources during assessment proceedings. The assessee satisfactorily explained that 98% of funds in circulation represented borrowed funds, and the outstanding debtors originated from income generated over time from money-lending activities. The ITAT held that the AO&#039;s view was plausible and not erroneous, citing established precedents that where two views are possible, the CIT cannot substitute the AO&#039;s reasonable conclusion with his own opinion.</description>
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      <title>2024 (12) TMI 906 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=763326</link>
      <description>The ITAT Chennai quashed the CIT&#039;s revision order under section 263. The CIT argued that the AO failed to properly examine incriminating search material regarding the assessee&#039;s money-lending business and outstanding debtors of Rs. 35 crores. However, the ITAT found that the AO had adequately inquired into the investment sources during assessment proceedings. The assessee satisfactorily explained that 98% of funds in circulation represented borrowed funds, and the outstanding debtors originated from income generated over time from money-lending activities. The ITAT held that the AO&#039;s view was plausible and not erroneous, citing established precedents that where two views are possible, the CIT cannot substitute the AO&#039;s reasonable conclusion with his own opinion.</description>
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