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2013 (12) TMI 183 - AT - Income TaxJurisdiction u/s 263 – Held that:- There is no finding in the order under section 263 as to how the assessment order u/s 147 is erroneous and prejudicial to the interests of the Revenue - The defect for assumption of jurisdiction in so far as all the materials were available to the AO which in the audited financial statements were verified - The doubts in the mind of the learned CIT to issue show-cause notice after the issue having been deliberated upon by the learned CIT was known to it when a copy of the order of the learned CIT(A) was also sent to the concerned CIT - Assumption of jurisdiction has been on misinterpretation of facts and non-application of mind because the learned CIT himself has directed the AO without pointing out any error prejudicial to the interests of the Revenue either to the assessee or to the AO – Decided in favour of assessee.
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