#section 263
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Section 263 can be invoked if no specific inquiry by AO against CBS expenses
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Revisional jurisdiction u/s 263 duly invoked as AO failed to examine issue of purchase of land
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Order passed after due application of mind cannot be subjected to proceeding u/s. 263
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Revisional jurisdiction u/s 263 not invocable merely because PCIT may entertain different view
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Invocation of section 263 justified if AO failed to enquire about non-deduction of TDS on CFS charges
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SC allows tax exemption to Trust Registered in year 1987 despite not applying for registration in 1997
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Proceedings u/s 263 unsustainable as enquiry already carried out by AO
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Section 263 cannot be Invoked if AO Adopted One of Two Plausible Views
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Reopening based on assessment record without tangible material is unsustainable
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Addition based on third person statement without giving any opportunity to cross examine is untenable
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Issue considered in order is open for revision if order is erroneous and prejudicial to interest of justice
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Netting of income u/s 57 allowed as there is direct nexus between interest received and paid
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Revisional jurisdiction u/s 263 not invocable as order passed by AO doesn’t satisfy twin conditions
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