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    <title>2021 (11) TMI 1230 - ITAT AHMEDABAD</title>
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    <description>Section 263 revision is sustainable only when the assessment order is both erroneous and prejudicial to the interests of the Revenue. Where the assessee&#039;s interest income was claimed to have been diverted at source by overriding title in favour of DICGCI, the income was treated as never reaching the assessee and therefore not taxable in its hands. Because that contention was not dealt with by the revisionary authority, the assessment could not be regarded as prejudicial to the Revenue for revision purposes. The revisionary order was quashed and the interference with the assessments was set aside.</description>
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    <pubDate>Tue, 30 Nov 2021 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=467880</link>
      <description>Section 263 revision is sustainable only when the assessment order is both erroneous and prejudicial to the interests of the Revenue. Where the assessee&#039;s interest income was claimed to have been diverted at source by overriding title in favour of DICGCI, the income was treated as never reaching the assessee and therefore not taxable in its hands. Because that contention was not dealt with by the revisionary authority, the assessment could not be regarded as prejudicial to the Revenue for revision purposes. The revisionary order was quashed and the interference with the assessments was set aside.</description>
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