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    <title>2026 (6) TMI 728 - ITAT CHENNAI</title>
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    <description>Section 263 revision was held unsustainable where the Assessing Officer had examined the reassessment record, called for details and adopted a permissible view on the genuineness of the mutual fund transaction. Mere disagreement by the Principal Commissioner did not satisfy the twin requirements that the order be both erroneous and prejudicial to the Revenue. The article also notes that the investment could not be characterised as a sham without cogent material showing the assessee&#039;s conscious participation in any colourable device, and that denial of dividend exemption and capital loss relief was unwarranted where the alleged regulatory breach, if any, lay with the fund. A direction extending to a later assessment year was treated as beyond revisional scope.</description>
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      <description>Section 263 revision was held unsustainable where the Assessing Officer had examined the reassessment record, called for details and adopted a permissible view on the genuineness of the mutual fund transaction. Mere disagreement by the Principal Commissioner did not satisfy the twin requirements that the order be both erroneous and prejudicial to the Revenue. The article also notes that the investment could not be characterised as a sham without cogent material showing the assessee&#039;s conscious participation in any colourable device, and that denial of dividend exemption and capital loss relief was unwarranted where the alleged regulatory breach, if any, lay with the fund. A direction extending to a later assessment year was treated as beyond revisional scope.</description>
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