Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
ITAT held that revision under section 263 was not justified because the AO had made adequate enquiry on cash sales, cash deposits, opening stock and purchases, and the assessee had furnished replies and records during assessment. The Tribunal found no lack of enquiry and held that the Principal Commissioner could not invoke revision merely to substitute a different view on the same material. Applying the principle that section 263 requires both error and prejudice to revenue, and that revision is unavailable where two plausible views exist, the Tribunal quashed the revisionary orders and allowed all three appeals.
ITAT held that revision under section 263 was not justified because the AO had made adequate enquiry on cash sales, cash deposits, opening stock and purchases, and the assessee had furnished replies and records during assessment. The Tribunal found no lack of enquiry and held that the Principal Commissioner could not invoke revision merely to substitute a different view on the same material. Applying the principle that section 263 requires both error and prejudice to revenue, and that revision is unavailable where two plausible views exist, the Tribunal quashed the revisionary orders and allowed all three appeals.
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