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    <title>2025 (2) TMI 1805 - ITAT NAGPUR</title>
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    <description>Section 263 revision was upheld where the assessment under section 143(3) followed a survey under section 133A but the Assessing Officer had not properly examined the impounded diary or verified the cash receipts and survey disclosure reflected in the seized material. The Tribunal treated the lack of enquiry into relevant impounded documents, including the difference between the amount disclosed and the amount appearing from the seized material, as sufficient to make the assessment order erroneous and prejudicial to the interests of the Revenue. It also noted that the assessee&#039;s own working on the impounded document was prepared only before the Tribunal, supporting the inference that necessary verification had not been done at assessment stage.</description>
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      <link>https://www.taxtmi.com/caselaws?id=468548</link>
      <description>Section 263 revision was upheld where the assessment under section 143(3) followed a survey under section 133A but the Assessing Officer had not properly examined the impounded diary or verified the cash receipts and survey disclosure reflected in the seized material. The Tribunal treated the lack of enquiry into relevant impounded documents, including the difference between the amount disclosed and the amount appearing from the seized material, as sufficient to make the assessment order erroneous and prejudicial to the interests of the Revenue. It also noted that the assessee&#039;s own working on the impounded document was prepared only before the Tribunal, supporting the inference that necessary verification had not been done at assessment stage.</description>
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