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    <title>2025 (3) TMI 1825 - ITAT DELHI</title>
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    <description>Section 263 revision was held unwarranted where the reassessment record showed active inquiry by the Assessing Officer, including a section 142(1) query, examination of the assessee&#039;s explanation, and consideration of confirmations and bank statements. The assessee&#039;s reply addressed the loan transaction with M/s Jar Metal Industries Private Limited, stating that the alleged amount was incorrect and that the actual loan was partly repaid with an outstanding balance. As no contrary material was brought on record, the assessment was based on inquiry and conscious application of mind, and the Principal Commissioner could not revise it merely because a different view was preferred. The revisional order was set aside and the assessee succeeded.</description>
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      <description>Section 263 revision was held unwarranted where the reassessment record showed active inquiry by the Assessing Officer, including a section 142(1) query, examination of the assessee&#039;s explanation, and consideration of confirmations and bank statements. The assessee&#039;s reply addressed the loan transaction with M/s Jar Metal Industries Private Limited, stating that the alleged amount was incorrect and that the actual loan was partly repaid with an outstanding balance. As no contrary material was brought on record, the assessment was based on inquiry and conscious application of mind, and the Principal Commissioner could not revise it merely because a different view was preferred. The revisional order was set aside and the assessee succeeded.</description>
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