https://www.taxtmi.com/caselaws?id=766372 Section 263 revision is stated to be unsustainable where the 14A read with Rule 8D disallowance had already been examined in assessment, was deleted in appeal, and no exempt-income basis justified the proposed adjustment; investment in a partnership firm and related profit were treated as insufficient on these facts. The text also states that compensation paid under a memorandum of understanding for cancellation was contractual business expenditure, not a penalty for breach of law, and therefore not inadmissible for revision purposes. The governing principle identified is that revision requires an order to be both erroneous and prejudicial to the Revenue. en-us Thu, 20 Feb 2025 00:00:00 +0530 Mon, 24 Feb 2025 08:05:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766372 Section 263 revision is stated to be unsustainable where the 14A read with Rule 8D disallowance had already been examined in assessment, was deleted in appeal, and no exempt-income basis justified the proposed adjustment; investment in a partnership firm and related profit were treated as insufficient on these facts. The text also states that compensation paid under a memorandum of understanding for cancellation was contractual business expenditure, not a penalty for breach of law, and therefore not inadmissible for revision purposes. The governing principle identified is that revision requires an order to be both erroneous and prejudicial to the Revenue. Case-Laws Income Tax Thu, 20 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766372