https://www.taxtmi.com/caselaws?id=339287 The court allowed the Writ Appeal, emphasizing the importance of considering the order under section 144A in the appellant's assessment and the broader powers under section 264 to provide relief to the assessee. The judgment clarified the distinction between sections 263 and 264 in terms of the scope of inquiry and highlighted that the Commissioner must consider all relevant material, including orders such as 144A, to prevent miscarriage of justice and ensure consistent treatment of transactions. The court's decision favored the appellant's revision request under section 264 of the Income Tax Act. en-us Wed, 15 Feb 2017 00:00:00 +0530 Sat, 17 Jun 2017 10:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=339287 The court allowed the Writ Appeal, emphasizing the importance of considering the order under section 144A in the appellant's assessment and the broader powers under section 264 to provide relief to the assessee. The judgment clarified the distinction between sections 263 and 264 in terms of the scope of inquiry and highlighted that the Commissioner must consider all relevant material, including orders such as 144A, to prevent miscarriage of justice and ensure consistent treatment of transactions. The court's decision favored the appellant's revision request under section 264 of the Income Tax Act. Case-Laws Income Tax Wed, 15 Feb 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=339287