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    <title>2025 (1) TMI 1066 - ITAT MUMBAI</title>
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    <description>The ITAT Mumbai held that the PCIT erred in exercising revision powers under section 263, finding the assessment order neither erroneous nor prejudicial to revenue interests. The tribunal determined that trade receivables from Municipal Solid Waste Division were never transferred to the assessee under the NCLT-sanctioned amalgamation scheme, contrary to PCIT&#039;s findings. The assessee had adequately explained the scheme details and provided supporting documentation including board resolutions during assessment proceedings. The AO had conducted proper inquiry regarding goodwill depreciation claims. The PCIT misconceived facts and wrongly assumed trade receivables were transferred, making the revision order unsustainable. Appeal decided in favor of assessee.</description>
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      <title>2025 (1) TMI 1066 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=765002</link>
      <description>The ITAT Mumbai held that the PCIT erred in exercising revision powers under section 263, finding the assessment order neither erroneous nor prejudicial to revenue interests. The tribunal determined that trade receivables from Municipal Solid Waste Division were never transferred to the assessee under the NCLT-sanctioned amalgamation scheme, contrary to PCIT&#039;s findings. The assessee had adequately explained the scheme details and provided supporting documentation including board resolutions during assessment proceedings. The AO had conducted proper inquiry regarding goodwill depreciation claims. The PCIT misconceived facts and wrongly assumed trade receivables were transferred, making the revision order unsustainable. Appeal decided in favor of assessee.</description>
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