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    <title>2025 (2) TMI 57 - BOMBAY HIGH COURT</title>
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    <description>Validity of revisional jurisdiction under Section 263 was examined in relation to computation of book profit under Section 115J. Court found assessing officer had not examined book profit at assessment, so the Commissioner&#039;s exercise of revision required and properly included observations on the merits to satisfy the twin conditions for jurisdiction; those observations were procedural and directed a fresh recomputation with opportunity to the assessee. Consequently the Commissioner&#039;s remarks were not conclusive findings on the substantive correctness of book profit and the revision order was valid; appeal by the assessee on merits was not permitted. Decision for revenue.</description>
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      <link>https://www.taxtmi.com/caselaws?id=765511</link>
      <description>Validity of revisional jurisdiction under Section 263 was examined in relation to computation of book profit under Section 115J. Court found assessing officer had not examined book profit at assessment, so the Commissioner&#039;s exercise of revision required and properly included observations on the merits to satisfy the twin conditions for jurisdiction; those observations were procedural and directed a fresh recomputation with opportunity to the assessee. Consequently the Commissioner&#039;s remarks were not conclusive findings on the substantive correctness of book profit and the revision order was valid; appeal by the assessee on merits was not permitted. Decision for revenue.</description>
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