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2012 (12) TMI 1032 - AT - Income TaxRevision u/s 263 - Held that:- A.O. has examined each and every of the issues, as per law. The order of ld. CIT is directory in the nature which is based on his own view as against the taken by the A.O. We don't find any lack of inquiry or even a case of inadequate inquiry. Under section 263, the commissioner cannot substitute his own view. He has not given any valid reason as to how the assessment order is erroneous. He has simply stated that the assessment order dated 7.1.2011 is erroneous and prejudicial to the interest of the revenue to that extent. The intention of this section is somewhat different. In case the A.O. has not made enquiries and taken an erroneous decision regarding an item of income, only then the order can be said to be erroneous on that point. A.O. takes a possible view qua a claim made and the ld. CIT takes another possible view, the order cannot be said to be erroneous.
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