https://www.taxtmi.com/caselaws?id=293586 Revision under section 263 was held unsustainable where the Assessing Officer had examined the joint venture agreement, balance sheet and notes to accounts, raised queries, and adopted a possible view on the material before him. The Tribunal held that a revisional authority cannot interfere merely because the assessment order is brief, because a later year is viewed differently, or because it prefers a different inference. It also found no basis to treat the arrangement as sham or to say there was no application of mind. The disputed tax consequence of the share transfer arose in the later year of transfer, not in the years under revision, and the assessments were restored. en-us Mon, 11 Mar 2019 00:00:00 +0530 Fri, 19 Feb 2021 10:33:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=293586 Revision under section 263 was held unsustainable where the Assessing Officer had examined the joint venture agreement, balance sheet and notes to accounts, raised queries, and adopted a possible view on the material before him. The Tribunal held that a revisional authority cannot interfere merely because the assessment order is brief, because a later year is viewed differently, or because it prefers a different inference. It also found no basis to treat the arrangement as sham or to say there was no application of mind. The disputed tax consequence of the share transfer arose in the later year of transfer, not in the years under revision, and the assessments were restored. Case-Laws Income Tax Mon, 11 Mar 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=293586