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    <title>2026 (2) TMI 308 - ITAT MUMBAI</title>
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    <description>Revision jurisdiction was examined where a revising officer altered an assessment despite the assessing officer having conducted a detailed inquiry; the reviser&#039;s findings were treated as a mere change of opinion and thus beyond permissible revision. The distinction between lack of inquiry and merely inadequate inquiry was emphasized, with Explanation 2 held inapplicable because inquiry had been made. A coordinate bench decision supported the view that the matter was debatable; consequently the revisional exercise was improper and the assessee&#039;s appeal succeeded.</description>
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