2008 (1) TMI 264

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....urt was delivered by C. N. RAMACHANDRAN NAIR J.— The question raised in this appeal filed by the assessee is against the validity of suo motu revisional proceedings completed by the Commissioner under section 263 of the Income-tax Act, 1961 and upheld by the Tribunal. The assessee was admittedly a contractor engaged in civil work. The receipt pertaining to income from contract was estimated at ....

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....is open to the assessee to contest the estimation of income. So far as the validity of section 263 proceedings is concerned, we are unable to accept the assessee's contention that the order passed by the officer is not prejudicial to the interests of the Revenue. If 90 per cent. of the expenses was allowed in the computation of income from contract, then the further claim of 90 per cent. against t....