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2018 (9) TMI 294 - HC - Income TaxRevision u/s 263 - action taken u/s 263 is only on the basis of the audit party's note or report - Held that:- Admittedly, the CIT has not referred to any audit objection but in the light of the note, the Tribunal held that it would be a fair inference that his action under Section 263 was consequent upon the audit objection. This office note clearly shows that the Assessing Officer had taken all explanations and arguments of the Assessee into consideration before allowing deduction. This being the case, the CIT could not have merely substituted his own views for that of the Assessing Officer by invoking Section 263. - Decided in favour of the Assessee and against the Revenue
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