https://www.taxtmi.com/caselaws?id=117482 Section 263 revision could not be used to withdraw a section 80HHC deduction that had already been decided in the assessee's favour on appeal, because the appellate decision attracted merger and the issue was no longer open to revision. Section 80-IA(9), as applied through section 80-IB(13), was treated as a limit on double deduction of the same profits beyond the eligible income, not as a complete bar on claiming another otherwise allowable Chapter VI-A deduction. The provision was contrasted with section 80-IC(5), which uses express prohibitory language where Parliament intends a total restriction. The revision was therefore unsustainable, subject to the cap that deductions on the same eligible profits cannot exceed 100 per cent. en-us Mon, 20 Jun 2005 00:00:00 +0530 Tue, 30 Apr 2024 14:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=117482 Section 263 revision could not be used to withdraw a section 80HHC deduction that had already been decided in the assessee's favour on appeal, because the appellate decision attracted merger and the issue was no longer open to revision. Section 80-IA(9), as applied through section 80-IB(13), was treated as a limit on double deduction of the same profits beyond the eligible income, not as a complete bar on claiming another otherwise allowable Chapter VI-A deduction. The provision was contrasted with section 80-IC(5), which uses express prohibitory language where Parliament intends a total restriction. The revision was therefore unsustainable, subject to the cap that deductions on the same eligible profits cannot exceed 100 per cent. Case-Laws Income Tax Mon, 20 Jun 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=117482