No revision possible invoking section 263 provisions on highly debate issue

Kalaivani Spinners Pvt. Ltd. Vs ITO (ITAT Chennai)

ITAT observed that PCIT himself admits that there are different views possible on claim of deduction u/s.80IA and issue is highly debatable. Once the issue is highly debatable no revision is possible invoking the provisions of section 263 of the Act. Hence, we quash the revision order passed by PCIT u/s.263 of the Act and allow the appeal of the assessee.”

FULL TEXT OF THE ORDER OF ITAT CHENN

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