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    <title>2026 (5) TMI 673 - ITAT SURAT</title>
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    <description>Section 263 revision could not be sustained where the assessment record showed inquiries under sections 142(1) and 133(6), including notices to parties and replies received. The absence of a detailed discussion in the assessment order did not by itself prove lack of enquiry. Reliance on GST data from the Insight Portal was insufficient because no categorical finding was recorded that the assessee had incurred unexplained expenditure from undisclosed sources, and the ledger accounts and bank statements were not shown to be false or fabricated. A third-party data discrepancy, without reconciliation or independent verification, did not establish that the assessment order was both erroneous and prejudicial to the Revenue.</description>
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