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    Revision u/s 263 and denial of deduction u/s 80IA: A Critical Analysis of the Delhi High Court's Jud...
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    Case LawsIncome Tax
    Revision u/s 263 and denial of deduction u/s 80IA: A Critical Analysis of the Delhi High Court's Jud...
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    Section 263 limited to substantial legal errors; mere differences of opinion don't justify revisional tax action.
    Scope of Section 263 is confined to instances where an assessment order is erroneous and prejudicial to revenue in a substantial way, not mere differences of opinion. Migration of licences from IP VPN to NLD ILD does not, by itself, create a new undertaking defeating entitlement to deduction under Section 80IA(4)(ii), particularly where identical deductions were previously allowed; administrative migration requires clear proof of substantive change before re characterising eligibility.

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