Section 263 Revision Limits: DIT Can't Overrule A.O's Decision on Section 44BB Interpretation of Income Tax Act.

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....Revision u/s 263 - scope of section 44BB - A.O after considering the various submissions made by the assessee from time to time and has taken a possible view, therefore, merely because the DIT does not agree with the opinion of the A.O, he cannot invoke the provisions of section 263 to substitute his own opinion - AT....