Revision u/s 263: Implications for Right Issue Shares and Section 56(2)(viib) of Income Tax Act for Residents Only.

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....Revision u/s 263 - Right issue shares - applicability of section 56(2)(viib) on the issue of shares by the company by stating that this section applied only to the residents and not to the non-residents - If the view point of the ld. PCIT is approved, it would give a licence to Pr. CITs to revise any assessment order in the second situation category cases without first satisfying the jurisdictional condition of showing the defect in the approach of the AO in accepting the assessee’s claim. - AT....