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    <title>2016 (6) TMI 1283 - ITAT AMRITSAR</title>
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    <description>Revision under section 263 was held invalid because the Assessing Officer had examined the depreciation claim on buses and adopted a plausible view that higher depreciation applied where the vehicles were used in a hire business; the revisional authority could not merely substitute a different opinion without showing the order was both erroneous and prejudicial to the Revenue. On section 14A, no disallowance was warranted where no exempt income had been earned and the assessment order was not shown to be legally unsustainable; the revisional action was also time-barred for earlier years under section 263(2). The revisional orders were set aside and the appeals were allowed.</description>
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      <title>2016 (6) TMI 1283 - ITAT AMRITSAR</title>
      <link>https://www.taxtmi.com/caselaws?id=199623</link>
      <description>Revision under section 263 was held invalid because the Assessing Officer had examined the depreciation claim on buses and adopted a plausible view that higher depreciation applied where the vehicles were used in a hire business; the revisional authority could not merely substitute a different opinion without showing the order was both erroneous and prejudicial to the Revenue. On section 14A, no disallowance was warranted where no exempt income had been earned and the assessment order was not shown to be legally unsustainable; the revisional action was also time-barred for earlier years under section 263(2). The revisional orders were set aside and the appeals were allowed.</description>
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