Income Tax Act Section 263 Revision Questions Allotment Letter Equivalence with DDA Under CBDT Circular No. 471.

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....Revision u/s 263 - Additions u/s 56(2)(vii)(b) - application of proviso is entirely a factual matter which has not been examined at all, and, in any event, it is a highly contentious issue whether an allotment letter issued by a private builder, even if that allotment be bonafide, can be equated with DDA allotments referred to in CBDT Circular no 471 dated 15.10.1986. - AT....