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2012 (3) TMI 485 - AT - Income TaxRevision u/s 263 - Held that:- The ideal situation to find out that Assessing Officer has investigated an issue in a purposeful manner is that discussion in respect of that issue should discern from the order itself. If no discussion is available in the order then it has to be gathered from the material available on record. On an analysis of the record, we find that Assessing Officer issued questionnaire on 7.4.2008. No specific details were submitted qua this issue in the letters submitted on the date of hearing taken place in between 23.4.2008 to 15.12.2008. In the details submitted during 263 proceedings and in the detail which alleged to have been submitted vide letter dated 15.12.2008, it is discernible that assessee has undertaken large number of transactions of 39 scripts. The record does not inspire credence with the angle that Assessing Officer has conducted a proper inquiry before accepting the claim of assessee. It gives an impression to us that at the close of the hearing at the most some information were placed on the record which appears to have not come to the notice of the Assessing Officer. In any case, it is not discernible that the Assessing Officer appears to have applied his mind analytically and logically and thereafter he took one of the possible view.
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