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    <title>2005 (6) TMI 211 - ITAT BANGALORE-B</title>
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    <description>Section 263 revision was held unsustainable where the Commissioner failed to identify an actual error in the assessment order and sought only further enquiry into foreign tax credit under the DTAA. The Tribunal held that, when the Assessing Officer had examined the claim and adopted one of the possible views, the order could not be treated as erroneous merely because another view was preferred. For assessment year 1994-95, the revision was also time-barred because limitation had to be counted from the original assessment order on the foreign tax credit, not from the later order giving effect to the appellate decision. Directions for fresh enquiry and recomputation were therefore invalid.</description>
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    <pubDate>Thu, 02 Jun 2005 00:00:00 +0530</pubDate>
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      <title>2005 (6) TMI 211 - ITAT BANGALORE-B</title>
      <link>https://www.taxtmi.com/caselaws?id=57813</link>
      <description>Section 263 revision was held unsustainable where the Commissioner failed to identify an actual error in the assessment order and sought only further enquiry into foreign tax credit under the DTAA. The Tribunal held that, when the Assessing Officer had examined the claim and adopted one of the possible views, the order could not be treated as erroneous merely because another view was preferred. For assessment year 1994-95, the revision was also time-barred because limitation had to be counted from the original assessment order on the foreign tax credit, not from the later order giving effect to the appellate decision. Directions for fresh enquiry and recomputation were therefore invalid.</description>
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