Allowing the appeal of the assessee the Tribunal held that, there being a decision by the jurisdictional High Court allowing the deduction of debenture redemption reserve above, it would be binding on the PCIT.  PCIT cannot hold that the order of Jurisdictional High Court is per in curium. The revision was based on a mere change of opinion and not because the original order was prejudicial to the interests of the revenue. Hence, the order of the PCIT is liable to be quashed on merits also.  Followed CIT v Raymond Ltd (2009) 2009  Taxman 65 (Bom.)(HC)and Grasim Industries Ltd. v. CIT  (2010) 321 ITR 92 (Bom.)(HC). (ITA. No. 3530/Mum/2018 (ITA. No. 3530/Mum/2018 / 3531 dt. 10-1-2019)(AY. 2009-10, 2010-11)