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    <title>2025 (4) TMI 2279 - ITAT AGRA</title>
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    <description>Revisionary jurisdiction under Section 263 requires an assessment order to be both erroneous and prejudicial to the interests of Revenue. Multiple assessment notices, taxpayer responses, examination of books, bills, vouchers, financial statements and the tax audit report demonstrated that enquiries had been undertaken. A lack of detailed discussion in the assessment order did not establish absence of enquiry where queries had been raised and answered. Further verification of partners&#039; capital after assessment also supported the existence of examination. As the revisional action identified no specific error causing revenue prejudice and merely sought broad further enquiries, its invocation was invalid; the original assessment was restored.</description>
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      <link>https://www.taxtmi.com/caselaws?id=472510</link>
      <description>Revisionary jurisdiction under Section 263 requires an assessment order to be both erroneous and prejudicial to the interests of Revenue. Multiple assessment notices, taxpayer responses, examination of books, bills, vouchers, financial statements and the tax audit report demonstrated that enquiries had been undertaken. A lack of detailed discussion in the assessment order did not establish absence of enquiry where queries had been raised and answered. Further verification of partners&#039; capital after assessment also supported the existence of examination. As the revisional action identified no specific error causing revenue prejudice and merely sought broad further enquiries, its invocation was invalid; the original assessment was restored.</description>
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