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    <title>2025 (2) TMI 1579 - ITAT MUMBAI</title>
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    <description>Explanation 2 to Section 263 treats an AO order as erroneous and prejudicial where required inquiries or verifications were not made; applied here to find no adequate inquiry into whether interest receipts were business income or income from other sources and no verification of nexus for claimed expenses. Because the AO issued only a single questionnaire and accepted returned income without further verification, the statutory condition in Explanation 2 was engaged and revision under Section 263 was sustainable; the revision was therefore upheld in favour of the revenue.</description>
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      <description>Explanation 2 to Section 263 treats an AO order as erroneous and prejudicial where required inquiries or verifications were not made; applied here to find no adequate inquiry into whether interest receipts were business income or income from other sources and no verification of nexus for claimed expenses. Because the AO issued only a single questionnaire and accepted returned income without further verification, the statutory condition in Explanation 2 was engaged and revision under Section 263 was sustainable; the revision was therefore upheld in favour of the revenue.</description>
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