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    <title>2026 (5) TMI 1546 - ITAT DELHI</title>
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    <description>Revision under section 263 could not be sustained where the reassessment had already been completed on the very issue for which it was reopened. The revisional authority sought to rely on survey material and other discrepancies outside the scope of the reopening, but section 263 applies only if the assessment order is both erroneous and prejudicial to the interests of the Revenue. As the reassessment was confined to a specific recorded reason and the addition was made on that basis, the order could not be revised on extraneous matters. The revisional order was quashed and the assessee succeeded on the jurisdictional challenge.</description>
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    <pubDate>Wed, 13 May 2026 00:00:00 +0530</pubDate>
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      <title>2026 (5) TMI 1546 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=792344</link>
      <description>Revision under section 263 could not be sustained where the reassessment had already been completed on the very issue for which it was reopened. The revisional authority sought to rely on survey material and other discrepancies outside the scope of the reopening, but section 263 applies only if the assessment order is both erroneous and prejudicial to the interests of the Revenue. As the reassessment was confined to a specific recorded reason and the addition was made on that basis, the order could not be revised on extraneous matters. The revisional order was quashed and the assessee succeeded on the jurisdictional challenge.</description>
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      <pubDate>Wed, 13 May 2026 00:00:00 +0530</pubDate>
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