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The HC held that the CIT's revision order u/s 263 was unsustainable. The CIT's view that the transfer of shares by the assessee was a sham to avoid DDT u/s 115-O was misplaced as the perceived DDT liability was on Genpact India, not the assessee Genpact Consulting. The Tribunal rightly concluded that in absence of the AO failing to make requisite inquiry, revision u/s 263 was unjustified. The Revenue failed to establish any additional tax liability on the assessee even if the CIT's view was correct.
The HC held that the CIT's revision order u/s 263 was unsustainable. The CIT's view that the transfer of shares by the assessee was a sham to avoid DDT u/s 115-O was misplaced as the perceived DDT liability was on Genpact India, not the assessee Genpact Consulting. The Tribunal rightly concluded that in absence of the AO failing to make requisite inquiry, revision u/s 263 was unjustified. The Revenue failed to establish any additional tax liability on the assessee even if the CIT's view was correct.
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