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    <title>2008 (1) TMI 906 - ITAT, DELHI</title>
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    <description>Revision under section 263 was held unsustainable because the Assessing Officer had examined the royalty expenditure and section 80HHC computation during reassessment and had adopted a permissible view on the material before him. The assessee had explained the contractual basis of the royalty claim, the timing of payment, and deduction of tax at source, so the record did not show an assessment made without enquiry. The alleged arithmetic error in the section 80HHC working was also not established, and no clear error prejudicial to the Revenue was demonstrated. The assessment order was restored and the revisional order set aside.</description>
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      <title>2008 (1) TMI 906 - ITAT, DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=181835</link>
      <description>Revision under section 263 was held unsustainable because the Assessing Officer had examined the royalty expenditure and section 80HHC computation during reassessment and had adopted a permissible view on the material before him. The assessee had explained the contractual basis of the royalty claim, the timing of payment, and deduction of tax at source, so the record did not show an assessment made without enquiry. The alleged arithmetic error in the section 80HHC working was also not established, and no clear error prejudicial to the Revenue was demonstrated. The assessment order was restored and the revisional order set aside.</description>
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