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    <title>2025 (2) TMI 1665 - ITAT HYDERABAD</title>
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    <description>Revision under Section 263 is confined to assessments that are both erroneous and prejudicial to revenue, and it cannot be used merely because the Principal Commissioner considers the Assessing Officer&#039;s inquiry insufficient. In this search-related Section 153A assessment, the Assessing Officer had called for a cash/funds flow statement and relied on the assessee&#039;s returns and other material to assess the source of funds for loan repayment. Because the record showed application of mind and a reasonable satisfaction on the relevant issue, no clear error or revenue prejudice was demonstrated. The Section 263 invocation was therefore held unsustainable and the assessee&#039;s appeal was allowed.</description>
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      <description>Revision under Section 263 is confined to assessments that are both erroneous and prejudicial to revenue, and it cannot be used merely because the Principal Commissioner considers the Assessing Officer&#039;s inquiry insufficient. In this search-related Section 153A assessment, the Assessing Officer had called for a cash/funds flow statement and relied on the assessee&#039;s returns and other material to assess the source of funds for loan repayment. Because the record showed application of mind and a reasonable satisfaction on the relevant issue, no clear error or revenue prejudice was demonstrated. The Section 263 invocation was therefore held unsustainable and the assessee&#039;s appeal was allowed.</description>
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