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    <title>2026 (8) TMI 944 - ITAT DELHI</title>
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    <description>Revision under section 263 cannot be sustained merely because the Assessing Officer allegedly allowed an excessive deduction for provision for bad and doubtful debts. The provision recorded in the profit and loss account was added back in computing taxable income, while the deduction under section 36(1)(viia) was separately quantified. The Assessing Officer sought and examined details of the provision and ICDS adjustments, including supporting computations. Where an assessment follows inquiry and application of mind, revision cannot be based on a different view; inadequate inquiry differs from absence of inquiry. The assessment was not erroneous or prejudicial to Revenue interests, and the revisionary order was quashed.</description>
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      <title>2026 (8) TMI 944 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=797070</link>
      <description>Revision under section 263 cannot be sustained merely because the Assessing Officer allegedly allowed an excessive deduction for provision for bad and doubtful debts. The provision recorded in the profit and loss account was added back in computing taxable income, while the deduction under section 36(1)(viia) was separately quantified. The Assessing Officer sought and examined details of the provision and ICDS adjustments, including supporting computations. Where an assessment follows inquiry and application of mind, revision cannot be based on a different view; inadequate inquiry differs from absence of inquiry. The assessment was not erroneous or prejudicial to Revenue interests, and the revisionary order was quashed.</description>
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