https://www.taxtmi.com/caselaws?id=446214 ITAT Kolkata held that CIT's revision u/s 263 was unjustified on two grounds. First, regarding double adjustment of long-term capital loss, the tribunal found it was an inadvertent mistake rectifiable u/s 154, not requiring revision u/s 263 as it didn't prejudice revenue or affect tax liability for the relevant year. Second, concerning DDT on proposed dividend, the tribunal ruled that DDT liability is distinct from income tax assessment u/s 143(3) and requires separate proceedings u/s 115Q. Since no separate DDT order existed, revision u/s 263 was inappropriate. The assessee's appeal was allowed. en-us Fri, 20 Oct 2023 00:00:00 +0530 Wed, 31 Jan 2024 14:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446214 ITAT Kolkata held that CIT's revision u/s 263 was unjustified on two grounds. First, regarding double adjustment of long-term capital loss, the tribunal found it was an inadvertent mistake rectifiable u/s 154, not requiring revision u/s 263 as it didn't prejudice revenue or affect tax liability for the relevant year. Second, concerning DDT on proposed dividend, the tribunal ruled that DDT liability is distinct from income tax assessment u/s 143(3) and requires separate proceedings u/s 115Q. Since no separate DDT order existed, revision u/s 263 was inappropriate. The assessee's appeal was allowed. Case-Laws Income Tax Fri, 20 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446214