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What is relevant for cl. (a) of Expln. 2 to s. 263 is whether the AO has passed the order after carrying out enquiries or verification, which a reasonable and prudent officer would have carried out or not.

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Section 263 of the Income Tax Act, 1961— Revision — Order of the AO cannot be held to be erroneous insofar as prejudicial to the interests of revenue as AO having examined the details of the expenses claimed against the interest income — Sthapathya Buildcon P. Ltd. vs. Deputy Commissioner of income tax [2020] 203 TTJ (Ahmedabad)(UO) 14

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