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    <title>2024 (10) TMI 1720 - ITAT KOLKATA</title>
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    <description>Revision under section 263 was treated as unsustainable where the Assessing Officer had issued detailed questionnaires, examined seized material, considered the assessee&#039;s replies and taken a legally permissible view after enquiry. The Tribunal noted that the assessments were completed with prior approval under section 153D, which was neither revised nor disturbed by the Principal Commissioner, and therefore a fresh enquiry on the same material could not justify revision. Explanation 2(a) to section 263 was held inapplicable because it does not authorise revision on a general allegation of inadequate enquiry; it applies only where requisite verification was not made. A plausible view taken after proper enquiry was not erroneous merely because another view was possible.</description>
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    <pubDate>Wed, 16 Oct 2024 00:00:00 +0530</pubDate>
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      <title>2024 (10) TMI 1720 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=464017</link>
      <description>Revision under section 263 was treated as unsustainable where the Assessing Officer had issued detailed questionnaires, examined seized material, considered the assessee&#039;s replies and taken a legally permissible view after enquiry. The Tribunal noted that the assessments were completed with prior approval under section 153D, which was neither revised nor disturbed by the Principal Commissioner, and therefore a fresh enquiry on the same material could not justify revision. Explanation 2(a) to section 263 was held inapplicable because it does not authorise revision on a general allegation of inadequate enquiry; it applies only where requisite verification was not made. A plausible view taken after proper enquiry was not erroneous merely because another view was possible.</description>
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