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    <title>2026 (5) TMI 481 - PATNA HIGH COURT</title>
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    <description>A challenge to revision under section 263 of the Income-tax Act failed because the real dispute was whether the Assessing Officer had conducted proper enquiry before completing scrutiny assessment under section 143(3). The Principal Commissioner sought revision on the basis of alleged lack of enquiry into taxability of a payment, deduction under section 35(2AB), and commission expenditure, but the Tribunal found that enquiry had in fact been made and that revision could not follow merely because a different view was preferred. The High Court treated the issue as one of fact, already resolved by the Tribunal, and held that no substantial question of law arose. The assessee therefore succeeded and the revision was not revived.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791279</link>
      <description>A challenge to revision under section 263 of the Income-tax Act failed because the real dispute was whether the Assessing Officer had conducted proper enquiry before completing scrutiny assessment under section 143(3). The Principal Commissioner sought revision on the basis of alleged lack of enquiry into taxability of a payment, deduction under section 35(2AB), and commission expenditure, but the Tribunal found that enquiry had in fact been made and that revision could not follow merely because a different view was preferred. The High Court treated the issue as one of fact, already resolved by the Tribunal, and held that no substantial question of law arose. The assessee therefore succeeded and the revision was not revived.</description>
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