Court Rules No Revision Needed for AO's Decision on Deemed Dividends Under Income Tax Act Section 2(22)(e.

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....Revision u/s 263 - Deemed dividend addition u/s 2(22)(e) - loan from group company being Non-Banking Financial Company - a conscious decision was taken by AO as regards the non-applicability of section 2(22)(e) to the loan amounts in question while completing the assessment under section 153A/143(3)- no revision....