S. 263 Revisionary power cannot be exercised on a debatable issue

HIGH COURT OF DELHI Commissioner of Income-tax, Delhi-IV versus DLF Ltd. S. RAVINDRA BHAT AND R.V. EASWAR, JJ. IT Appeal Nos. 236 & 384 OF 2010 SEPTEMBER 17, 2012 JUDGMENT S. Ravindra Bhat, J. The Revenue in these appeals is aggrieved by orders of the Tribunal dated 7.11.2008 (in ITA No. 2004/Del/2007) and dated 3.6.2009 (in ITA-1137/B/2009). The question of law sought to be urged is “Whether the Tribunal fell into error in holding that the provisions of Section-263 of the Act could not be invoked having regard to the facts and circumstances of the present case....