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    <title>2025 (1) TMI 173 - ITAT DELHI</title>
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    <description>Section 263 revision was unsustainable where the Assessing Officer had adopted a plausible view on the TDS treatment of external development charges paid to HUDA. The Tribunal noted that the payment classification under section 194I versus section 194C was debatable, the issue was already pending in appeal, and the later High Court ruling relied on by the revisional authority had been stayed. On the record then available, the Assessing Officer&#039;s view was a possible view and the Revenue also failed to establish prejudice, since the rate applied was higher than the section 194C rate. The revisional order was quashed.</description>
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      <title>2025 (1) TMI 173 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=764111</link>
      <description>Section 263 revision was unsustainable where the Assessing Officer had adopted a plausible view on the TDS treatment of external development charges paid to HUDA. The Tribunal noted that the payment classification under section 194I versus section 194C was debatable, the issue was already pending in appeal, and the later High Court ruling relied on by the revisional authority had been stayed. On the record then available, the Assessing Officer&#039;s view was a possible view and the Revenue also failed to establish prejudice, since the rate applied was higher than the section 194C rate. The revisional order was quashed.</description>
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