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2012 (6) TMI 472 - AT - Income TaxRevision u/s 263 initiated on two grounds - (i) the A.O. had not verified the applicability of sec. 92 of the Act before allowing export turnover of the assessee; and (ii) sufficient enquiry had not been carried out in respect of the lenders while allowing receipt of unsecured loans by the assessee-company to the tune of ₹ 1.63 crores. - held that:- when on the facts and circumstances of the case and evidence on record there was no requirement of taking into consideration the list of associated enterprises, more so when there was no international transaction with them, the A.O. did not commit any mistake in not asking for such list. - Revision on first ground is not valid. C.I.T. observed that the A.O. did not make proper enquiries about the creditworthiness of the lenders before accepting the loans to the assessee. - held that:- In the case of the assessee, the ld. C.I.T. could not point out as to what was the error committed by the A.O. in not having considered the applicability of Sec. 92 of the Act and in accepting the unsecured loan taken by the assessee. The ld. C.I.T. having failed to point out such error, no error can be inferred from the order of A.O. for the simple reason that the same is bereft of details. - Revision u/s 263 on second ground is also not valid. - Decided in favor of assessee.
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