https://www.taxtmi.com/caselaws?id=450129 ITAT Pune held that revision proceedings under section 263 were invalid where the AO had adopted one of two legally possible views regarding section 36(1)(viia) deduction for provision for standard assets. Different ITAT benches had taken varying positions on allowability of such deductions, with some treating standard asset provisions as deductible bad and doubtful debts. Since the AO's view was legally tenable among conflicting precedents, the assessment order could not be deemed erroneous or prejudicial to revenue interests, making the CIT's section 263 order legally unsustainable. The assessee's appeal was allowed. en-us Mon, 26 Feb 2024 00:00:00 +0530 Wed, 28 Feb 2024 08:36:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450129 ITAT Pune held that revision proceedings under section 263 were invalid where the AO had adopted one of two legally possible views regarding section 36(1)(viia) deduction for provision for standard assets. Different ITAT benches had taken varying positions on allowability of such deductions, with some treating standard asset provisions as deductible bad and doubtful debts. Since the AO's view was legally tenable among conflicting precedents, the assessment order could not be deemed erroneous or prejudicial to revenue interests, making the CIT's section 263 order legally unsustainable. The assessee's appeal was allowed. Case-Laws Income Tax Mon, 26 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450129