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of <h1>Delhi High Court: Differing Opinions Don't Justify Section 263 Powers; Telecom Licenses Migration Not New Under 80IA.</h1> In a significant case, the Delhi High Court addressed the interpretation of Sections 263 and 80IA of the Income Tax Act concerning a telecom company's tax assessment for AY 2010-11. The court examined whether the Principal Commissioner of Income Tax (PCIT) was justified in using revisional powers under Section 263, concluding that mere differences in opinion between the Assessing Officer and the PCIT do not warrant its invocation. Additionally, the court ruled that the migration of licenses did not constitute a new undertaking under Section 80IA, thus maintaining the company's eligibility for deductions. This judgment underscores the need for consistency and fairness in tax assessments.
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