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    <title>2023 (10) TMI 552 - ITAT DELHI</title>
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    <description>Section 263 revision cannot be sustained where the Assessing Officer adopted one permissible view on the taxability of surrendered income under section 115BBE. The record showed that the income was already offered in the return, tax was paid, and no addition was made under sections 68 or 69. Because the applicability of the amended section 115BBE was treated as debatable, the assessment order could not be characterised as both erroneous and prejudicial to the interests of the Revenue. Revisional power cannot be used to substitute another view on a debatable issue.</description>
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      <link>https://www.taxtmi.com/caselaws?id=444329</link>
      <description>Section 263 revision cannot be sustained where the Assessing Officer adopted one permissible view on the taxability of surrendered income under section 115BBE. The record showed that the income was already offered in the return, tax was paid, and no addition was made under sections 68 or 69. Because the applicability of the amended section 115BBE was treated as debatable, the assessment order could not be characterised as both erroneous and prejudicial to the interests of the Revenue. Revisional power cannot be used to substitute another view on a debatable issue.</description>
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