The twin conditions required for invoking revisional jurisdiction u/s. 263 viz. (a). the order of A.O. sought to be revised is erroneous; and (ii). it is prejudicial to the interest of the revenue. The view taken by the A.O. which is found to be in conformity with the Hon’ble High Court of Karnataka in the case of CIT v. I-Gate Global Solutions Ltd. (ITA No. 452/2008 dt. 17-6-2015) could not have been held to be erroneous. (AY. 2009-10, 2011-12)
Shell India Markets Private Limited v. CIT (2020) 206 TTJ 405 (Mum.)(Trib.)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-View of the Assessing Officer is in conformity with the view of judgement of High Court-Revision is held to be not valid.[S.144C]