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    <title>2025 (7) TMI 1354 - ITAT NAGPUR</title>
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    <description>The ITAT Nagpur held that the AO&#039;s assessment completed under section 144, exercising best judgment due to inadequate response from the assessee, cannot be deemed erroneous or prejudicial to revenue. The revision under section 263 by the PCIT was improper, as the AO&#039;s order under section 144 is absolute and not subject to being set aside merely because the PCIT disagreed with the profit estimation. The conditions for invoking section 263 were absent since the AO had made a considered decision with available material. The appeal against the revision order was allowed.</description>
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      <title>2025 (7) TMI 1354 - ITAT NAGPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=775286</link>
      <description>The ITAT Nagpur held that the AO&#039;s assessment completed under section 144, exercising best judgment due to inadequate response from the assessee, cannot be deemed erroneous or prejudicial to revenue. The revision under section 263 by the PCIT was improper, as the AO&#039;s order under section 144 is absolute and not subject to being set aside merely because the PCIT disagreed with the profit estimation. The conditions for invoking section 263 were absent since the AO had made a considered decision with available material. The appeal against the revision order was allowed.</description>
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      <pubDate>Mon, 10 Feb 2025 00:00:00 +0530</pubDate>
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