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Revisional jurisdiction over an assessment allowing deduction of...
Revisional jurisdiction over export quota premium deductions requires both error and Revenue prejudice; a permissible assessment view cannot be displaced.
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Revisional jurisdiction over an assessment allowing deduction of export quota sale premium as business profits is limited to orders that are both erroneous and prejudicial to the interests of the Revenue. A permissible assessment view cannot be revised solely because the Commissioner takes a different view, unless the assessment position is unsustainable in law. The statutory treatment of export quota premium, administrative tax guidance, and the Tribunal's interpretation are relevant in determining whether the deduction is legally sustainable and whether revisional intervention is justified.
Revisional jurisdiction over an assessment allowing deduction of export quota sale premium as business profits is limited to orders that are both erroneous and prejudicial to the interests of the Revenue. A permissible assessment view cannot be revised solely because the Commissioner takes a different view, unless the assessment position is unsustainable in law. The statutory treatment of export quota premium, administrative tax guidance, and the Tribunal's interpretation are relevant in determining whether the deduction is legally sustainable and whether revisional intervention is justified.
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