CIT's Use of Section 263 Deemed Impermissible as It Constitutes a Change of Opinion on Slump Sale Explanation.

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....Revision u/s 263 - change of opinion - in proceedings u/s 147 assessee contended that the transfer price was based on the individual assets and liabilities of the undertaking transferred and the sale would not qualify as “Slump Sale” as per Section 2(42C) - this explanation of the Assessee was accepted by the AO - for the very same reasons, the CIT has invoked the power u/s 263 - not permissible....