CIT's reclassification of allowed amount as contingent liability seen as opinion shift; jurisdiction principles don't support it.

CIT's reclassification of allowed amount as contingent liability seen as opinion shift; jurisdiction principles don't support it. https://www.taxtmi.com/highlights?id=22175 Revision u/s 263 -opinion of CIT in treating the amount already allowed as contingent liability can certainly be considered as change of opinion. On the principles governing the issue of jurisdiction, we cannot uphold the direction of the Ld. CIT - AT en-us Sat, 21 Mar 2015 08:06:26 +0530 Sat, 21 Mar 2015 08:06:26 +0530 TaxTMI RSS Generator CIT's reclassification of allowed amount as contingent liability seen as opinion shift; jurisdiction principles don't support it. https://www.taxtmi.com/highlights?id=22175 Revision u/s 263 -opinion of CIT in treating the amount already allowed as contingent liability can certainly be considered as change of opinion. On the principles governing the issue of jurisdiction, we cannot uphold the direction of the Ld. CIT - AT Highlights Income Tax Sat, 21 Mar 2015 08:06:26 +0530 https://www.taxtmi.com/highlights?id=22175