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ITAT held that the Pr. CIT's revision under s. 263 challenging an assessment passed under s. 153A read with s. 143(3) in respect of carbon-credit receipts failed because the incriminating materials relied on by the AO were held by the CIT(A) to be non-incriminating, thereby vitiating the foundation for reassessment; the assessee's appeal on this limb was allowed. Conversely, ITAT upheld the Pr. CIT's exercise of s. 263 jurisdiction to rectify erroneous computation of deduction under s. 80IA where the AO omitted allocation of head-office expenses and other costs, causing prejudice; such specific apportionment fell within "such matters" warranting revision, and the assessee's appeal on this issue was dismissed.
ITAT held that the Pr. CIT's revision under s. 263 challenging an assessment passed under s. 153A read with s. 143(3) in respect of carbon-credit receipts failed because the incriminating materials relied on by the AO were held by the CIT(A) to be non-incriminating, thereby vitiating the foundation for reassessment; the assessee's appeal on this limb was allowed. Conversely, ITAT upheld the Pr. CIT's exercise of s. 263 jurisdiction to rectify erroneous computation of deduction under s. 80IA where the AO omitted allocation of head-office expenses and other costs, causing prejudice; such specific apportionment fell within "such matters" warranting revision, and the assessee's appeal on this issue was dismissed.
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