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of Revision u/s 263 - Penny stock purchases - penny stock SOP guidelines have been issued by CBDT only in respect of listed scrips. - The scrip in question is not listed in any stock exchange - the SOP guidelines issued by CBDT cannot be made applicable for unlisted scrips. Hence the ld. PCIT had assumed revision jurisdiction on incorrect assumption of fact and incorrect application of CBDT guidelines. - AT
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