https://www.taxtmi.com/caselaws?id=179978 The dominant issue was whether revision under s.263 was valid on the ground that the AO granted deduction under s.80-IB(10) without examining statutory conditions, particularly the date of commencement of development/construction. The HC held that the assessee had furnished built-up area details and calculations, and the statutory audit report disclosed approval dates for each housing project, showing the AO was aware of material facts. In the absence of a statutory definition of "commencement," the determination had to be made pragmatically, and the issue was debatable with more than one plausible view. Since the AO had adopted a plausible view, the assessment was neither "erroneous" nor "prejudicial to the interests of the Revenue," and the s.263 revision was set aside. en-us Mon, 24 Sep 2012 00:00:00 +0530 Wed, 07 Jan 2026 11:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=179978 The dominant issue was whether revision under s.263 was valid on the ground that the AO granted deduction under s.80-IB(10) without examining statutory conditions, particularly the date of commencement of development/construction. The HC held that the assessee had furnished built-up area details and calculations, and the statutory audit report disclosed approval dates for each housing project, showing the AO was aware of material facts. In the absence of a statutory definition of "commencement," the determination had to be made pragmatically, and the issue was debatable with more than one plausible view. Since the AO had adopted a plausible view, the assessment was neither "erroneous" nor "prejudicial to the interests of the Revenue," and the s.263 revision was set aside. Case-Laws Income Tax Mon, 24 Sep 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=179978