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    <title>2025 (12) TMI 1577 - ITAT DELHI</title>
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    <description>Revision under section 263 was considered invalid where the Assessing Officer had queried the assessee on interest under section 28 of the Land Acquisition Act, accepted the explanation after enquiry, and adopted a plausible view that such interest formed part of enhanced compensation and was exempt. A brief assessment order did not by itself show lack of enquiry, and the revisional authority could not invoke section 263 merely because it preferred another view or relied on an audit objection. The text also notes that dismissal of an earlier special leave petition did not override the Supreme Court&#039;s view treating section 28 interest as compensation. On these facts, the assessment was not revisable.</description>
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      <link>https://www.taxtmi.com/caselaws?id=784037</link>
      <description>Revision under section 263 was considered invalid where the Assessing Officer had queried the assessee on interest under section 28 of the Land Acquisition Act, accepted the explanation after enquiry, and adopted a plausible view that such interest formed part of enhanced compensation and was exempt. A brief assessment order did not by itself show lack of enquiry, and the revisional authority could not invoke section 263 merely because it preferred another view or relied on an audit objection. The text also notes that dismissal of an earlier special leave petition did not override the Supreme Court&#039;s view treating section 28 interest as compensation. On these facts, the assessment was not revisable.</description>
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