https://www.taxtmi.com/caselaws?id=260682 Section 263 revision was held impermissible where the Assessing Officer had examined the development agreement, possession, consideration and asset character before taking a possible view that no capital gain accrued in the relevant year. Revision was also barred on depreciation because the IT Park building issue had already merged with an appellate order. For the later year, the same depreciation issue remained outside revision for the same reason, but the donation deduction was allowed without proper inquiry, making the assessment erroneous and prejudicial to revenue. Rectification under section 154 did not prevent revision on that issue. The revision was therefore quashed for the capital gains and depreciation matters, but sustained for the donation claim. en-us Tue, 09 Jun 2015 00:00:00 +0530 Sat, 20 Jun 2015 08:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=260682 Section 263 revision was held impermissible where the Assessing Officer had examined the development agreement, possession, consideration and asset character before taking a possible view that no capital gain accrued in the relevant year. Revision was also barred on depreciation because the IT Park building issue had already merged with an appellate order. For the later year, the same depreciation issue remained outside revision for the same reason, but the donation deduction was allowed without proper inquiry, making the assessment erroneous and prejudicial to revenue. Rectification under section 154 did not prevent revision on that issue. The revision was therefore quashed for the capital gains and depreciation matters, but sustained for the donation claim. Case-Laws Income Tax Tue, 09 Jun 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=260682