Where two views are possible and AO has taken one view, CIT cannot exercise his
powers under section 263 to differ with view of AO even if there has been a loss
of revenue
The expression prejudicial to the interest of revenue appearing in Section 263
has to be read in conjunction with the expression "erroneous" and every loss of
revenue as a consequence of an order of the Assessing Officer cannot be treated
as prejudicial to the interest of the revenue
[2010] 6 taxmann.com 15 (Delhi)
HIGH COURT OF DELHI
CIT
v.
Honda Siel Power Products Ltd.