https://www.taxtmi.com/caselaws?id=59932 The dominant issue was whether the CIT validly assumed revisionary jurisdiction under s.263 on three grounds. On deduction of technical fees/drawings, the CIT gave no reasons or material to treat the outlay as capital and, despite remand, recorded a factual finding that foreclosed meaningful reconsideration; since the AO had adopted a possible and reasonable view, revision was without jurisdiction and was set aside on this issue. On alleged colourable device in borrowing on interest and advancing interest-free funds, the CIT's inference lacked evidentiary basis; revisionary directions were held unsustainable. On s.80M, absent any specific expenditure proved for earning dormant dividend income, no notional allocation could be made; the AO's view was reasonable and revision was quashed. The impugned s.263 order was set aside and the appeal allowed. en-us Thu, 12 Sep 2002 00:00:00 +0530 Thu, 08 Jan 2026 14:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59932 The dominant issue was whether the CIT validly assumed revisionary jurisdiction under s.263 on three grounds. On deduction of technical fees/drawings, the CIT gave no reasons or material to treat the outlay as capital and, despite remand, recorded a factual finding that foreclosed meaningful reconsideration; since the AO had adopted a possible and reasonable view, revision was without jurisdiction and was set aside on this issue. On alleged colourable device in borrowing on interest and advancing interest-free funds, the CIT's inference lacked evidentiary basis; revisionary directions were held unsustainable. On s.80M, absent any specific expenditure proved for earning dormant dividend income, no notional allocation could be made; the AO's view was reasonable and revision was quashed. The impugned s.263 order was set aside and the appeal allowed. Case-Laws Income Tax Thu, 12 Sep 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59932