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    <title>2026 (6) TMI 132 - ITAT DELHI</title>
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    <description>Section 263 revision was held unsustainable where the Assessing Officer had examined the scrutiny triggers, sought replies and considered the material before completing assessment. The Tribunal held that revision cannot be based on mere inadequacy of enquiry or a roving and fishing inquiry when the Assessing Officer has taken a plausible view. It also held that a fresh ground on expense verification could not be introduced in the revision order because it was not part of the show-cause notice. The alleged liability transfer by journal entry under a tripartite arrangement did not establish the requisite error and prejudice to justify revisional jurisdiction, so the revisionary order was quashed and the assessment restored.</description>
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      <link>https://www.taxtmi.com/caselaws?id=792751</link>
      <description>Section 263 revision was held unsustainable where the Assessing Officer had examined the scrutiny triggers, sought replies and considered the material before completing assessment. The Tribunal held that revision cannot be based on mere inadequacy of enquiry or a roving and fishing inquiry when the Assessing Officer has taken a plausible view. It also held that a fresh ground on expense verification could not be introduced in the revision order because it was not part of the show-cause notice. The alleged liability transfer by journal entry under a tripartite arrangement did not establish the requisite error and prejudice to justify revisional jurisdiction, so the revisionary order was quashed and the assessment restored.</description>
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