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Income Tax Commissioner Revises AO's Zero Assessment of Trust, Citing Commercial Nature u/s 263 and Section 2(15.

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....Revision u/s 263 by CIT - the AO despite having recorded that though the assessee trust’s activity fall under the ambit of “general public utility”, they are of commercial in nature and are covered by first and second proviso of section 2(15) - However, he erroneously assessed income of the assessee at Rs.NIL. - it is the clear case where the assessment order is erroneous and self-contradictory. - AT....