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    <title>2026 (6) TMI 915 - ITAT NAGPUR</title>
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    <description>The ITAT upheld revision under section 263 where the Assessing Officer had accepted additional income from unrecorded sales without proper verification of related purchases, the profit element in the transactions, or the applicability of sections 69A and 115BBE. It found that no contemporaneous evidence supporting the alleged expenditure was examined at assessment, and that the invoices were produced only in revision proceedings. On that basis, the Tribunal held the assessment was made without adequate inquiry and fell within Explanation 2 to section 263, which treats an order as erroneous and prejudicial when necessary verification has not been done. The challenge to the direction for fresh assessment failed.</description>
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      <description>The ITAT upheld revision under section 263 where the Assessing Officer had accepted additional income from unrecorded sales without proper verification of related purchases, the profit element in the transactions, or the applicability of sections 69A and 115BBE. It found that no contemporaneous evidence supporting the alleged expenditure was examined at assessment, and that the invoices were produced only in revision proceedings. On that basis, the Tribunal held the assessment was made without adequate inquiry and fell within Explanation 2 to section 263, which treats an order as erroneous and prejudicial when necessary verification has not been done. The challenge to the direction for fresh assessment failed.</description>
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