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Income tax Commissioner before exercising power of revision has to be satisfied of twin conditions, namely, (i) the order of the AO sought to be revised is erroneous ; and (ii) it is prejudicial to the interests of the Revenue.
On the first condition the Allahabad High Court in [2020] 420 ITR 216 (All)held that a scrutiny assessment made after detailed questionnaire and verification can’t be rated as erroneous only because some aspects left to be uncovered.
In this case as many as 28 point questionnaire is issued to the taxpayer and inquired into and even after that the Commissioner initiated revision seeking extended examination of unsecured loans and creditors.
So any show cause u/s 263 seeking extended verification of any item can be challenged where the case has undergone a detailed scrutiny.

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