CIT's reclassification of allowed amount as contingent liability seen as opinion shift; jurisdiction principles don't support it.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Revision u/s 263 -opinion of CIT in treating the amount already allowed as contingent liability can certainly be considered as change of opinion. On the principles governing the issue of jurisdiction, we cannot uphold the direction of the Ld. CIT - AT....