https://www.taxtmi.com/caselaws?id=415681 The Tribunal allowed the appeal, quashing the CIT's order under Section 263 and restoring the original assessment order by the A.O. It was held that the A.O's view on set-off of losses was plausible, rendering the CIT's revisional jurisdiction unjustified. Section 79 was deemed inapplicable due to ultimate control resting with the holding company despite shareholding changes. The Tribunal referenced relevant case law to support its decision, emphasizing the A.O's obligation to favor the assessee in case of conflicting judgments. en-us Fri, 12 Nov 2021 00:00:00 +0530 Sat, 11 Dec 2021 09:26:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=415681 The Tribunal allowed the appeal, quashing the CIT's order under Section 263 and restoring the original assessment order by the A.O. It was held that the A.O's view on set-off of losses was plausible, rendering the CIT's revisional jurisdiction unjustified. Section 79 was deemed inapplicable due to ultimate control resting with the holding company despite shareholding changes. The Tribunal referenced relevant case law to support its decision, emphasizing the A.O's obligation to favor the assessee in case of conflicting judgments. Case-Laws Income Tax Fri, 12 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=415681