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    <title>2026 (7) TMI 512 - GUJARAT HIGH COURT</title>
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      <description>The revisional order under section 263 had to be judged only on the material existing when that order was made, so the Tribunal could not rely on a later assessment order passed pursuant to the revisional direction to justify the original assumption of jurisdiction. A hindsight-based review of the revisional action was impermissible where the validity of section 263 itself was under challenge. The impugned order was quashed and the Tribunal was directed to hear the appeal afresh; the question was answered in favour of the assessee and against the revenue.</description>
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