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Revision u/s 263 - non consideration of the provisions of Section 40(a)(i-a) in respect of land development expenses - the CIT had proceeded to remand the matter back to the AO while the appeal of the assessee was pending u/s 250 and the power of exercise u/s 263 was barred by Clause (c) to Explanation 1 of Section 263 - no interference in the order of the ITAT called far