No Revision under section 263 if AO had made specific enquiry into loan transactions of assessee based on the CASS parameter.

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No Revision under section 263 if AO had made specific enquiry into loan transactions of assessee based on the CASS parameter.

short Overview : AO had made specific enquiry into loan transactions of assessee based on the CASS parameter. In response to enquiries made under section 133(6), loan creditors had filed their documents/details to substantiate/prove their identity(ies), creditworthiness and genuineness of the loan transactions. AO having examined all the details had not drawn any adverse inference against any loan creditors and did not follow a view ‘unsustainable in law’ and assessment order was not the result of non-application of mind or any inadequate enquiry, accordingly, invocation of jurisdiction under section 263 was untenable.

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