https://www.taxtmi.com/caselaws?id=456840 The ITAT Chennai allowed the assessee's appeal against revision proceedings under section 263. The tribunal held that the AO's assessment treating call option termination proceeds as capital gains under section 45 was a plausible view, not erroneous or prejudicial to revenue interests. The CIT's argument regarding invalid section 142(1) notices without DIN was rejected since the assessee wasn't at fault and the assessment considered the reply. The tribunal found no non-compete element in the termination agreement to invoke section 28(va) provisions. The AO had adequately considered the transaction's nature during assessment proceedings, making revision unjustified. en-us Fri, 08 Sep 2023 00:00:00 +0530 Tue, 20 Aug 2024 23:42:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456840 The ITAT Chennai allowed the assessee's appeal against revision proceedings under section 263. The tribunal held that the AO's assessment treating call option termination proceeds as capital gains under section 45 was a plausible view, not erroneous or prejudicial to revenue interests. The CIT's argument regarding invalid section 142(1) notices without DIN was rejected since the assessee wasn't at fault and the assessment considered the reply. The tribunal found no non-compete element in the termination agreement to invoke section 28(va) provisions. The AO had adequately considered the transaction's nature during assessment proceedings, making revision unjustified. Case-Laws Income Tax Fri, 08 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456840