Sports Club of Gujarat Ltd. v. PCIT (2022) 195 ITD 373 (Ahd.) (Trib.)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Club entrance fee-Capital receipt-Revision is held to be not valid. [S. 4, 143(3)]

Held that for past 12 years i.e. from the assessment year 2004-05 onwards had been receiving an entrance fee and had been treating the same as its capital receipt, and all these years, the stand of the assessee had been accepted by revenue. Without bringing on record any material change in facts from previous years, Principal Commissioner had erred in passing the revision order. (AY. 2015-16)