PCIT Revises Tax Order u/s 263: Share Transfer Profits Unexamined, Assessment Found Erroneous and Prejudicial to Revenue.

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....Revision u/s 263 - Doctrine of merger - When the issue flagged by Ld. PCIT has never been ascertained/examined to compute the correct book profit qua the transfer of these shares there is no question of merger of the order. Moreover, when the assessment order is apparently erroneous so far as prejudicial to the interest of the Revenue having been decided by the AO in favour of the assessee without ascertaining or examining the same order passed by Ld. PCIT does not call for any interference by the Tribunal. - AT....