Religious purpose exclusion versus charitable purpose: non overriding religious objects do not attract Explanation 3, registration directed under sect...
Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
Dominant issue: Whether the assessing officer's allowance of deduction under s.80P(2)(a)(i)/80P(2)(d) for interest and dividend from co-operative banks was an erroneous exercise of jurisdiction warranting revision under s.263. Reasoning: The AO made specific enquiries, verified records, and adopted a plausible, debatable view; the issue is covered by an earlier consistent finding favourable to the assessee. Outcome: The revisionary jurisdiction under s.263 cannot be invoked as the AO's order, though potentially prejudicial to Revenue, is not erroneous; appeal allowed for assessee. - ITAT
Dominant issue: Whether the assessing officer's allowance of deduction under s.80P(2)(a)(i)/80P(2)(d) for interest and dividend from co-operative banks was an erroneous exercise of jurisdiction warranting revision under s.263. Reasoning: The AO made specific enquiries, verified records, and adopted a plausible, debatable view; the issue is covered by an earlier consistent finding favourable to the assessee. Outcome: The revisionary jurisdiction under s.263 cannot be invoked as the AO's order, though potentially prejudicial to Revenue, is not erroneous; appeal allowed for assessee. - ITAT
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