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    <title>2021 (12) TMI 767 - BOMBAY HIGH COURT</title>
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    <description>Where a deduction dispute under Section 80IA/80IB had already been examined by the appellate authority and decided on merits by the Tribunal, the assessment order merged in the appellate order and revisional jurisdiction under Section 263 was unavailable on the same issue. The revisional action was therefore invalid. Since the penalty under Section 271(1)(c) was consequential to that revisional disallowance and the deduction claim had already been upheld in appeal, the concealment penalty also could not be sustained. Both the revisional order and the consequential penalty order were held unsustainable.</description>
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    <pubDate>Mon, 06 Dec 2021 00:00:00 +0530</pubDate>
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      <title>2021 (12) TMI 767 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=416001</link>
      <description>Where a deduction dispute under Section 80IA/80IB had already been examined by the appellate authority and decided on merits by the Tribunal, the assessment order merged in the appellate order and revisional jurisdiction under Section 263 was unavailable on the same issue. The revisional action was therefore invalid. Since the penalty under Section 271(1)(c) was consequential to that revisional disallowance and the deduction claim had already been upheld in appeal, the concealment penalty also could not be sustained. Both the revisional order and the consequential penalty order were held unsustainable.</description>
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      <pubDate>Mon, 06 Dec 2021 00:00:00 +0530</pubDate>
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