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    <title>2024 (1) TMI 1469 - CALCUTTA HIGH COURT</title>
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    <description>HC upheld the Tribunal&#039;s decision that the Principal Commissioner of Income Tax (PCIT) lacked jurisdiction under section 263 to revise the assessment a second time on the same issue, as no reasons were provided for the revision. The Tribunal found the assessee had furnished complete details during both assessments and substantiated the genuineness of transactions. It concluded the assessing officer&#039;s view in the second assessment was legally permissible. The Tribunal also relied on a similar precedent from a Coordinate Bench, determining there was no non-application of mind or failure to reappreciate facts by the assessing officer. Consequently, the Tribunal granted relief to the assessee, which HC affirmed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=462520</link>
      <description>HC upheld the Tribunal&#039;s decision that the Principal Commissioner of Income Tax (PCIT) lacked jurisdiction under section 263 to revise the assessment a second time on the same issue, as no reasons were provided for the revision. The Tribunal found the assessee had furnished complete details during both assessments and substantiated the genuineness of transactions. It concluded the assessing officer&#039;s view in the second assessment was legally permissible. The Tribunal also relied on a similar precedent from a Coordinate Bench, determining there was no non-application of mind or failure to reappreciate facts by the assessing officer. Consequently, the Tribunal granted relief to the assessee, which HC affirmed.</description>
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