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    <title>2026 (4) TMI 1530 - ITAT NAGPUR</title>
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    <description>A revisional order under section 263 was found unsustainable where the scrutiny assessment had already examined the relevant material and accepted the claim, and the revision was initiated beyond the limitation period measured from the original assessment order. The Tribunal also accepted the assessee&#039;s explanation for delayed filing, treating the delay as unintentional and condoning it in favour of substantial justice. Once the revision was quashed, the consequential addition made in the giving-effect assessment had no , and the related penalty also fell with it. The connected appeals were thus allowed, with the revision, addition, and penalty all set aside.</description>
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      <link>https://www.taxtmi.com/caselaws?id=790461</link>
      <description>A revisional order under section 263 was found unsustainable where the scrutiny assessment had already examined the relevant material and accepted the claim, and the revision was initiated beyond the limitation period measured from the original assessment order. The Tribunal also accepted the assessee&#039;s explanation for delayed filing, treating the delay as unintentional and condoning it in favour of substantial justice. Once the revision was quashed, the consequential addition made in the giving-effect assessment had no , and the related penalty also fell with it. The connected appeals were thus allowed, with the revision, addition, and penalty all set aside.</description>
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