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Revision under section 263 is sustainable only where the assessment order is both erroneous and prejudicial to the Revenue; a revisional authority cannot merely substitute its own view for a plausible assessment or direct additions without lawful re-examination. The Tribunal also noted that a provision for doubtful debts remained allowable where debtors were correspondingly reduced, foreign dividend deduction under section 80M was not overridden by section 115BBD, festival and pooja expenses supported by business records were not personal, taxes paid under protest could still qualify on actual payment, GST credit reversal loss from fire required factual support, and section 54EC relief was not denied merely because section 50 applied for computation.
Revision under section 263 is sustainable only where the assessment order is both erroneous and prejudicial to the Revenue; a revisional authority cannot merely substitute its own view for a plausible assessment or direct additions without lawful re-examination. The Tribunal also noted that a provision for doubtful debts remained allowable where debtors were correspondingly reduced, foreign dividend deduction under section 80M was not overridden by section 115BBD, festival and pooja expenses supported by business records were not personal, taxes paid under protest could still qualify on actual payment, GST credit reversal loss from fire required factual support, and section 54EC relief was not denied merely because section 50 applied for computation.
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