https://www.taxtmi.com/caselaws?id=447971 Delhi HC ruled against revenue in a Section 263 revision case where PCIT denied Section 80IA(4)(ii) deduction previously allowed since AY 2007-08. Court held that PCIT cannot invoke Section 263 jurisdiction merely because of disagreement with Assessing Officer's view when both views are legally permissible. Revenue failed to prove that migration from IP-VPN to NLD-ILD license created a new undertaking disqualifying the deduction. Court emphasized that mere service addition or expansion doesn't disqualify Section 80IA benefits, citing established precedents that revenue loss alone doesn't justify Section 263 intervention. en-us Fri, 05 Jan 2024 00:00:00 +0530 Thu, 29 Aug 2024 11:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447971 Delhi HC ruled against revenue in a Section 263 revision case where PCIT denied Section 80IA(4)(ii) deduction previously allowed since AY 2007-08. Court held that PCIT cannot invoke Section 263 jurisdiction merely because of disagreement with Assessing Officer's view when both views are legally permissible. Revenue failed to prove that migration from IP-VPN to NLD-ILD license created a new undertaking disqualifying the deduction. Court emphasized that mere service addition or expansion doesn't disqualify Section 80IA benefits, citing established precedents that revenue loss alone doesn't justify Section 263 intervention. Case-Laws Income Tax Fri, 05 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447971