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    <title>2026 (2) TMI 1184 - ITAT DELHI</title>
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    <description>Whether revisionary powers under Section 263 were rightly invoked: the tribunal applied the principle that revision is permissible only where the assessment order is both erroneous and prejudicial to revenue and where there is a lack of inquiry. Because the Assessing Officer had reopened the assessment, examined cash deposits, obtained schedules and audited balance-sheet entries, and accepted explanations, the essential condition of lack of inquiry was not met. Re-appreciation of audited classifications by the revisional authority amounted to a change of opinion, not correction of an erroneous assessment; accordingly the revision order was quashed and the appeal allowed for the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=787036</link>
      <description>Whether revisionary powers under Section 263 were rightly invoked: the tribunal applied the principle that revision is permissible only where the assessment order is both erroneous and prejudicial to revenue and where there is a lack of inquiry. Because the Assessing Officer had reopened the assessment, examined cash deposits, obtained schedules and audited balance-sheet entries, and accepted explanations, the essential condition of lack of inquiry was not met. Re-appreciation of audited classifications by the revisional authority amounted to a change of opinion, not correction of an erroneous assessment; accordingly the revision order was quashed and the appeal allowed for the assessee.</description>
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