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    <title>2025 (12) TMI 1701 - ITAT AGRA</title>
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    <description>Revision under s. 263 on alleged bogus purchases turned on whether the assessment was &quot;erroneous and prejudicial to the interests of the Revenue.&quot; The Tribunal held the AO had made independent enquiry, recorded third-party and assessee personnel statements, and adopted a possible view accepting the purchases; the revisional authority failed to record a clear finding of error and prejudice and proceeded on suspicion without showing absence of enquiry or independent adverse material. Consequently, the s. 263 order was set aside and the assessee&#039;s grounds were allowed. On reassessment additions for purchases of raw boneless meat, the Tribunal upheld the appellate finding that exports and corresponding sales were accepted, stock/yield was not doubted, payments were through banking channels, and the &quot;round-tripping&quot; inference lacked year-specific material; the deletion of additions was sustained.</description>
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    <pubDate>Thu, 04 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1701 - ITAT AGRA</title>
      <link>https://www.taxtmi.com/caselaws?id=784161</link>
      <description>Revision under s. 263 on alleged bogus purchases turned on whether the assessment was &quot;erroneous and prejudicial to the interests of the Revenue.&quot; The Tribunal held the AO had made independent enquiry, recorded third-party and assessee personnel statements, and adopted a possible view accepting the purchases; the revisional authority failed to record a clear finding of error and prejudice and proceeded on suspicion without showing absence of enquiry or independent adverse material. Consequently, the s. 263 order was set aside and the assessee&#039;s grounds were allowed. On reassessment additions for purchases of raw boneless meat, the Tribunal upheld the appellate finding that exports and corresponding sales were accepted, stock/yield was not doubted, payments were through banking channels, and the &quot;round-tripping&quot; inference lacked year-specific material; the deletion of additions was sustained.</description>
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      <pubDate>Thu, 04 Dec 2025 00:00:00 +0530</pubDate>
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