https://www.taxtmi.com/caselaws?id=456999 The Tribunal dismissed the appeal, affirming the CIT's jurisdiction under Section 263 of the IT Act. It held that the assessment order was erroneous and prejudicial to the interests of the Revenue due to the AO's failure to exclude supervision charges from business profits under Clause (baa) of the Explanation to Section 80 HHC. The Tribunal emphasized that the doctrine of merger did not apply, as the specific issue was neither considered nor decided by the CIT(A). Consequently, the CIT's order for a fresh assessment was justified, and the AO's oversight warranted the exercise of revisional powers. en-us Wed, 04 Sep 2002 00:00:00 +0530 Fri, 30 Aug 2024 16:41:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456999 The Tribunal dismissed the appeal, affirming the CIT's jurisdiction under Section 263 of the IT Act. It held that the assessment order was erroneous and prejudicial to the interests of the Revenue due to the AO's failure to exclude supervision charges from business profits under Clause (baa) of the Explanation to Section 80 HHC. The Tribunal emphasized that the doctrine of merger did not apply, as the specific issue was neither considered nor decided by the CIT(A). Consequently, the CIT's order for a fresh assessment was justified, and the AO's oversight warranted the exercise of revisional powers. Case-Laws Income Tax Wed, 04 Sep 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456999