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    <title>2022 (9) TMI 1703 - ITAT COCHIN</title>
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    <description>Revision under section 263 can be sustained where the Assessing Officer accepts a return without examining a prima facie relevant issue, because lack of enquiry can render the assessment order both erroneous and prejudicial to the interests of revenue. In this matter, the assessment was revised on the ground that no examination was made of the tax treatment of mark-to-market gains from derivative and forward contracts recognised on accrual basis in the profit and loss account. As there was no material showing that the issue had been considered during assessment, the revisional authority&#039;s finding of inadequate enquiry was upheld and the revision was held valid.</description>
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      <description>Revision under section 263 can be sustained where the Assessing Officer accepts a return without examining a prima facie relevant issue, because lack of enquiry can render the assessment order both erroneous and prejudicial to the interests of revenue. In this matter, the assessment was revised on the ground that no examination was made of the tax treatment of mark-to-market gains from derivative and forward contracts recognised on accrual basis in the profit and loss account. As there was no material showing that the issue had been considered during assessment, the revisional authority&#039;s finding of inadequate enquiry was upheld and the revision was held valid.</description>
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