https://www.taxtmi.com/caselaws?id=764391 ITAT Mumbai quashed CIT(E)'s revisional order under Section 263 directing verification of Section 11 exemption. The assessee acted purely as custodial agent for State Government with no ownership of collected funds (lease premiums), making income non-taxable in its hands. ITAT relied on SC ruling in Ahmedabad Urban Development Authority establishing similar activities were non-commercial. Court held Section 263 cannot be invoked based on change of opinion, and since income nature was already examined and no new sources identified, the revisional order was unjustified. Assessee's appeal allowed. en-us Mon, 06 Jan 2025 00:00:00 +0530 Wed, 08 Jan 2025 13:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764391 ITAT Mumbai quashed CIT(E)'s revisional order under Section 263 directing verification of Section 11 exemption. The assessee acted purely as custodial agent for State Government with no ownership of collected funds (lease premiums), making income non-taxable in its hands. ITAT relied on SC ruling in Ahmedabad Urban Development Authority establishing similar activities were non-commercial. Court held Section 263 cannot be invoked based on change of opinion, and since income nature was already examined and no new sources identified, the revisional order was unjustified. Assessee's appeal allowed. Case-Laws Income Tax Mon, 06 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764391