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    <title>2025 (6) TMI 704 - ITAT PUNE</title>
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    <description>Revision under section 263 was held unjustified where the Assessing Officer had issued specific queries on the allowability of provision for construction expenditure and defect warranty, and the assessee had furnished replies with supporting material before assessment under section 143(3). The assessment record showed enquiry and application of mind, so the order could not be treated as passed without requisite verification. Explanation 2(a) to section 263(1) does not permit revision merely because the Principal Commissioner considers the enquiry inadequate or prefers a deeper scrutiny when a plausible view has already been taken after examination. The revisional order was therefore unsustainable and set aside.</description>
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      <title>2025 (6) TMI 704 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=772591</link>
      <description>Revision under section 263 was held unjustified where the Assessing Officer had issued specific queries on the allowability of provision for construction expenditure and defect warranty, and the assessee had furnished replies with supporting material before assessment under section 143(3). The assessment record showed enquiry and application of mind, so the order could not be treated as passed without requisite verification. Explanation 2(a) to section 263(1) does not permit revision merely because the Principal Commissioner considers the enquiry inadequate or prefers a deeper scrutiny when a plausible view has already been taken after examination. The revisional order was therefore unsustainable and set aside.</description>
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