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Validity of revision proceedings u/s 263 - Adoption of either of ...


Assessment Order Upheld: Revision by Tax Commissioner Invalidated Due to Plausible Interpretation by Assessing Officer.

February 28, 2024

Case Laws     Income Tax     AT

Validity of revision proceedings u/s 263 - Adoption of either of view by AO - allowability under section 36(1)(viia) - The court concludes that the original assessment order was not erroneous or prejudicial to the interest of revenue. It holds that the AO's decision was based on a possible view, and therefore, the revision proceedings initiated by the PCIT under section 263 are deemed invalid. Consequently, the appeal of the assessee is allowed.

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