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    <title>2025 (2) TMI 1792 - ITAT NAGPUR</title>
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    <description>Revision under section 263 was not sustainable where the assessment addition based on seized loose papers and estimated marketing income had already been deleted in appeal. The first appellate authority had found the papers unreliable and insufficient, so the same subject matter could not be reopened in revision under Explanation 1(c) to section 263. The revisional authority also went beyond the show-cause notice by directing fresh enquiries on matters not proposed in the notice, which could not support the exercise of revisional jurisdiction. On these facts, the assessment order was not shown to be erroneous and prejudicial to the interests of the revenue for section 263 purposes.</description>
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      <title>2025 (2) TMI 1792 - ITAT NAGPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=468423</link>
      <description>Revision under section 263 was not sustainable where the assessment addition based on seized loose papers and estimated marketing income had already been deleted in appeal. The first appellate authority had found the papers unreliable and insufficient, so the same subject matter could not be reopened in revision under Explanation 1(c) to section 263. The revisional authority also went beyond the show-cause notice by directing fresh enquiries on matters not proposed in the notice, which could not support the exercise of revisional jurisdiction. On these facts, the assessment order was not shown to be erroneous and prejudicial to the interests of the revenue for section 263 purposes.</description>
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