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2023 (5) TMI 1092 - AT - Income TaxRevision u/s 263 - As per CIT AO without making enquiry allowed the expenses which are not allowable in nature as a business expenditure - HELD THAT:- No evidence or material coming from assessee to substantiate that the AO has made any enquiry with respect to the twin-expenses noted by PCIT. No query having been raised by AO with respect to impugned twin-expenses claimed by assessee. AR is not able to demonstrate as to how the AO has enquired or verified the impugned claim of expenses made by assessee. No hesitation in observing that the present case perfectly fits in Explanation 2 to section 263, as re-produced earlier, according to which an order passed by the AO is deemed to be erroneous if (a) the order is passed without making inquiries or verification which should have been made; or (b) the order is passed allowing any relief without inquiring into the claim. Being so, we uphold the impugned revision-order Decided against assessee.
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