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    <title>2018 (7) TMI 577 - ITAT DELHI</title>
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    <description>The Tribunal found in favor of the assessee on all issues. It held that the assessing officer&#039;s failure to assess the revenue receipt of Passenger Service Fee (PSF) for the assessment year 2007-08 resulted in under-assessment of tax. However, the Tribunal concluded that the security component of the PSF did not constitute income in the hands of the assessee, as evidenced by contractual agreements. Additionally, the Tribunal ruled that the jurisdiction exercised by the Learned CIT under section 263 of the Income Tax Act could not be sustained, as the issues were debatable and not conclusively decided, ultimately allowing the appeal and quashing the CIT&#039;s order under section 263 of the Act.</description>
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      <title>2018 (7) TMI 577 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=363269</link>
      <description>The Tribunal found in favor of the assessee on all issues. It held that the assessing officer&#039;s failure to assess the revenue receipt of Passenger Service Fee (PSF) for the assessment year 2007-08 resulted in under-assessment of tax. However, the Tribunal concluded that the security component of the PSF did not constitute income in the hands of the assessee, as evidenced by contractual agreements. Additionally, the Tribunal ruled that the jurisdiction exercised by the Learned CIT under section 263 of the Income Tax Act could not be sustained, as the issues were debatable and not conclusively decided, ultimately allowing the appeal and quashing the CIT&#039;s order under section 263 of the Act.</description>
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