Dismissing the appeal of the Revenue the Court held that, the Tribunal came to a finding of fact that the Assessing Officer had taken a possible view in the matter and there was nothing to indicate that the Assessing Officer had applied the provisions on an incorrect way. Since the view taken by the Assessing Officer was a possible view, the Principal Commissioner had assumed jurisdiction under section 263 without properly complying with the mandate of section 263. No substantial questions of law. (AY. 2011-12)
PCIT v. American Spring & Pressing Works (P.) Ltd. (2023) 295 Taxman 438 (Bom.)(HC) Editorial: American Spring & Pressing Works (P.) Ltd v. PCIT (2017) 166 ITD 92 (Mum)(Trib), affirmed.
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Development of residential complex-Land converted into stock in trade-Possible view-Order of Tribunal is affirmed. [S. 2(47)(v), 45(2), 260A]