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    <title>2022 (2) TMI 1344 - ITAT DELHI</title>
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    <description>Section 263 revision was sustained because the assessment order accepted the assessee&#039;s claim on taxability of interest on enhanced compensation without showing any clear enquiry or reasoning. Where the issue was governed by conflicting views, the Assessing Officer was required to demonstrate application of mind and consider the binding jurisdictional High Court view that such interest was taxable as income from other sources. The absence of a reasoned examination supported a finding of lack of enquiry, and a later judicial view could not cure that defect in the completed assessment. The order was therefore treated as erroneous and prejudicial to the interests of revenue.</description>
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      <link>https://www.taxtmi.com/caselaws?id=306575</link>
      <description>Section 263 revision was sustained because the assessment order accepted the assessee&#039;s claim on taxability of interest on enhanced compensation without showing any clear enquiry or reasoning. Where the issue was governed by conflicting views, the Assessing Officer was required to demonstrate application of mind and consider the binding jurisdictional High Court view that such interest was taxable as income from other sources. The absence of a reasoned examination supported a finding of lack of enquiry, and a later judicial view could not cure that defect in the completed assessment. The order was therefore treated as erroneous and prejudicial to the interests of revenue.</description>
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