Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
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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