https://www.taxtmi.com/highlights?id=61219 Revision u/s 263 by CIT - addition of share premium - addition u/s 68 - Pr. CIT has made a bald statement that the AO’s assessment order attracts Explanation 2(c) u/s. 263 of the Act. However, he failed to spell out in his impugned order how the action of AO while framing the assessment order is not in accordance to any order, direction or instruction issued by the Board under section 119 of the Act. So, the deeming fiction as envisaged in Explanation (2) u/s. 263 of the Act cannot be used to interfere with the order of AO. - AT en-us Fri, 31 Dec 2021 11:17:44 +0530 Fri, 31 Dec 2021 11:17:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=61219 Revision u/s 263 by CIT - addition of share premium - addition u/s 68 - Pr. CIT has made a bald statement that the AO’s assessment order attracts Explanation 2(c) u/s. 263 of the Act. However, he failed to spell out in his impugned order how the action of AO while framing the assessment order is not in accordance to any order, direction or instruction issued by the Board under section 119 of the Act. So, the deeming fiction as envisaged in Explanation (2) u/s. 263 of the Act cannot be used to interfere with the order of AO. - AT Highlights Income Tax Fri, 31 Dec 2021 11:17:44 +0530 https://www.taxtmi.com/highlights?id=61219