https://www.taxtmi.com/caselaws?id=11756 The dominant issue was whether the Commissioner validly invoked revision under s.263 to withdraw relief (under s.80J/related deduction) on the ground that the assessment was "erroneous and prejudicial to the interests of the Revenue." Applying SC law that s.263 lies only where the AO's view is unsustainable in law and not merely because another view is possible, the HC held that the assessee's consistent, departmentally accepted method of apportioning common expenses between old and new units was rational and not shown to be improper; concurrent factual findings on apportionment could not be disturbed. Consequently, the Tribunal's quashing of the s.263 order and restoration of the AO's assessment was upheld, and the reference was answered for the assessee. en-us Wed, 02 Apr 2003 00:00:00 +0530 Sun, 28 Dec 2025 23:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=11756 The dominant issue was whether the Commissioner validly invoked revision under s.263 to withdraw relief (under s.80J/related deduction) on the ground that the assessment was "erroneous and prejudicial to the interests of the Revenue." Applying SC law that s.263 lies only where the AO's view is unsustainable in law and not merely because another view is possible, the HC held that the assessee's consistent, departmentally accepted method of apportioning common expenses between old and new units was rational and not shown to be improper; concurrent factual findings on apportionment could not be disturbed. Consequently, the Tribunal's quashing of the s.263 order and restoration of the AO's assessment was upheld, and the reference was answered for the assessee. Case-Laws Income Tax Wed, 02 Apr 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=11756