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    <title>2025 (7) TMI 424 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai held that CIT&#039;s revision u/s 263 was invalid as the assessment order was neither erroneous nor prejudicial to revenue interest. The AO had made specific enquiries during scrutiny assessment on issues including Section 115JB, disallowance u/s 14A, bad debts, interest on perpetual bonds, and RBI penalties, receiving specific replies from the assessee. Other issues like broken period interest, amortization on securities, and unrealized interest on doubtful debts were already decided favorably for assessee by SC and HC. Since twin conditions of being both erroneous and prejudicial to revenue were not satisfied, revision jurisdiction could not be assumed. Assessee&#039;s appeal was allowed.</description>
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      <title>2025 (7) TMI 424 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=774356</link>
      <description>ITAT Mumbai held that CIT&#039;s revision u/s 263 was invalid as the assessment order was neither erroneous nor prejudicial to revenue interest. The AO had made specific enquiries during scrutiny assessment on issues including Section 115JB, disallowance u/s 14A, bad debts, interest on perpetual bonds, and RBI penalties, receiving specific replies from the assessee. Other issues like broken period interest, amortization on securities, and unrealized interest on doubtful debts were already decided favorably for assessee by SC and HC. Since twin conditions of being both erroneous and prejudicial to revenue were not satisfied, revision jurisdiction could not be assumed. Assessee&#039;s appeal was allowed.</description>
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      <pubDate>Fri, 20 Jun 2025 00:00:00 +0530</pubDate>
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