Section 263

Delhi H.C : A bare reading of this provision makes it clear that the prerequisite to the exercise of jurisdiction by the CIT suo motu under it, is that the order of the ITO is erroneous insofar as it is prejudicial to the interests of the Revenue. The CIT has to be satisfied of twin conditions, namely, (i) the order of the AO sought to be revised is erroneous; and (ii) it is prejudicial to the interests of the Revenue

High Court Of Delhi CIT vs. Vikram Aditya & Associates (P)Ltd. Sections 94(7), 263 Asst. Year 2001-02 Madan B. Lokur

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