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2018 (9) TMI 618 - AT - Income TaxRevision u/s 263 - deduction u/s 80P(2)(a)(i) against interest income earned by the assessee - ‘no inquiry’ OR ‘lack of inquiry’ or ‘inadequate inquiry’ - Held that:- The justification of claiming deduction against bank interest has neither been adduced / substantiated by the assessee nor being examined / verified by the AO. Nothing on record suggests any application of mind on the issue by Ld. AO. This being the case, we find no force in the submissions of Ld. AR that the issue was examined by Ld. AO with due application of mind and the deduction was allowed after due deliberations. The aforesaid factual matrix lead us to conclude that the case falls under the category of ‘no inquiry’ rather than ‘lack of inquiry’ or ‘inadequate inquiry’ as contended by Ld. AR. In such a case, the reliance placed by Ld. AR on various judicial pronouncements could not help the assessee, in any manner. Therefore, the order being clearly erroneous as well as prejudicial to the interest of the revenue justifies invocation of jurisdiction u/s 263. - Decided against assessee.
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