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    <title>2026 (5) TMI 1142 - ITAT DELHI</title>
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    <description>Section 263 revision could not be sustained where the reassessment order was not shown to be erroneous or prejudicial merely because a different tax view was possible. Jewellery purchase expenditure found during search was treated as having been incurred by the company from unaccounted cash generated through bogus billing, and the record did not establish any employer-employee relationship necessary to tax the amount as a perquisite under section 17(2). On those facts, addition in the assessee&#039;s hands under section 17(2) was unjustified and revision was not warranted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791940</link>
      <description>Section 263 revision could not be sustained where the reassessment order was not shown to be erroneous or prejudicial merely because a different tax view was possible. Jewellery purchase expenditure found during search was treated as having been incurred by the company from unaccounted cash generated through bogus billing, and the record did not establish any employer-employee relationship necessary to tax the amount as a perquisite under section 17(2). On those facts, addition in the assessee&#039;s hands under section 17(2) was unjustified and revision was not warranted.</description>
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