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    <title>Revision under section 263 turns on whether assessment enquiry was made, not a substantial question of law.</title>
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    <description>The determinative issue was whether the Assessing Officer had made the enquiry required before the Principal Commissioner invoked revision under section 263. The High Court treated that enquiry question as a pure question of fact, and held that the Tribunal&#039;s finding on it could not be converted into a substantial question of law under section 260A. As the Revenue&#039;s challenge depended on whether assessment proceedings were conducted with or without enquiry, the appeal was not entertainable on the basis urged and was rejected.</description>
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      <description>The determinative issue was whether the Assessing Officer had made the enquiry required before the Principal Commissioner invoked revision under section 263. The High Court treated that enquiry question as a pure question of fact, and held that the Tribunal&#039;s finding on it could not be converted into a substantial question of law under section 260A. As the Revenue&#039;s challenge depended on whether assessment proceedings were conducted with or without enquiry, the appeal was not entertainable on the basis urged and was rejected.</description>
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