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Section 263 revision was examined on multiple alleged errors in...
Insurer's investment gains and investment write-downs face Section 263 revision; enquiry upheld, Rule 5(b)(ii) lapse sustained, late corrigendum quashed
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Section 263 revision was examined on multiple alleged errors in an insurer's assessment. On exemption/profit on sale of investments, the record showed the gains were included in total income and the AO had made specific enquiries; hence the assessment was not "erroneous and prejudicial," and revision was set aside on this issue. On provision for diminution in value of investments (actively traded equities), the assessee admitted mismatch with Rule 5(b)(ii) and the AO had not examined it; revision was sustained and the assessee's challenge failed on this issue. Disallowance under section 14A/Rule 8D and MAT add-backs for IBNR/IBNER and unexpired risk were held inapplicable/already examined, so revision was annulled on those issues. A time-barred corrigendum introducing a new issue was quashed. - ITAT
Section 263 revision was examined on multiple alleged errors in an insurer's assessment. On exemption/profit on sale of investments, the record showed the gains were included in total income and the AO had made specific enquiries; hence the assessment was not "erroneous and prejudicial," and revision was set aside on this issue. On provision for diminution in value of investments (actively traded equities), the assessee admitted mismatch with Rule 5(b)(ii) and the AO had not examined it; revision was sustained and the assessee's challenge failed on this issue. Disallowance under section 14A/Rule 8D and MAT add-backs for IBNR/IBNER and unexpired risk were held inapplicable/already examined, so revision was annulled on those issues. A time-barred corrigendum introducing a new issue was quashed. - ITAT
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