S. 263 If two views possible CIT have to agree with AO’s even if there is a loss of revenue

JUDGEMENT BADAR DURREZ AHMED, J 1. These appeals were heard together and are being disposed of by this common judgement inasmuch as the question of law framed in both the appeals is identical and the circumstances are also virtually identical. The question of law that has been framed in these appeals is as under:- “Whether the Income Tax Appellate Tribunal was correct in law in cancelling the order passed by the Commissioner of Income Tax under Section 263 and in restoring the order of the Assessing Officer by holding that the Assessing Officer had taken a possible view at the relevant p...