Department's Action u/s 263 Contradicts CBDT Circular, Initiates Litigation Ignoring Issued Clarifications in Assessments.

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....Revision u/s 263 - As been emphasized by the CBDT that the pending assessment and litigations should be handled taking into consideration the clarification so issued and in the instant case, a fresh litigation has been started by the Department by initiation of action u/s 263 which is clearly in the teeth of the CBDT Circular and cannot be sustained in the eyes of law. - AT....