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    <title>2025 (7) TMI 1975 - ITAT MUMBAI</title>
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    <description>Revision of assessment on the write off of a loan to a joint venture raised the question whether the assessing officer had failed to examine earlier year entries and apply mind, justifying exercise of revisional jurisdiction. The tribunal found the assessing officer had issued notices and received replies, and that two reasonable views existed on allowability and capital-versus-revenue character; where AO applies mind and takes one view, exercise of revisional powers is impermissible. Comparative decisions showing mere non inquiry were distinguished. Consequently the revisional order was quashed and the assessee&#039;s appeal allowed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=466515</link>
      <description>Revision of assessment on the write off of a loan to a joint venture raised the question whether the assessing officer had failed to examine earlier year entries and apply mind, justifying exercise of revisional jurisdiction. The tribunal found the assessing officer had issued notices and received replies, and that two reasonable views existed on allowability and capital-versus-revenue character; where AO applies mind and takes one view, exercise of revisional powers is impermissible. Comparative decisions showing mere non inquiry were distinguished. Consequently the revisional order was quashed and the assessee&#039;s appeal allowed.</description>
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