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    <title>2026 (8) TMI 44 - ITAT NAGPUR</title>
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    <description>Revisionary jurisdiction under section 263 cannot be invoked merely because the Assessing Officer could have conducted further or more extensive enquiries. Specific notices, explanations, books, bank records, confirmations, invoices, e-way bills, GST records and affidavits were examined, and additions were made after considering seized material. A finding that an assessment is erroneous and unsustainable requires support from the assessment record or an independent enquiry. The revision proceedings also overlooked a rectification order enhancing the accommodation-entry addition and did not examine the record of prior assessment approval. The section 263 order was therefore quashed.</description>
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      <title>2026 (8) TMI 44 - ITAT NAGPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=796171</link>
      <description>Revisionary jurisdiction under section 263 cannot be invoked merely because the Assessing Officer could have conducted further or more extensive enquiries. Specific notices, explanations, books, bank records, confirmations, invoices, e-way bills, GST records and affidavits were examined, and additions were made after considering seized material. A finding that an assessment is erroneous and unsustainable requires support from the assessment record or an independent enquiry. The revision proceedings also overlooked a rectification order enhancing the accommodation-entry addition and did not examine the record of prior assessment approval. The section 263 order was therefore quashed.</description>
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