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1998 (9) TMI 128 - ITAT INDORE
Extract:
.......s stated above is a matter of debate. Looked at from this perspective also, as the issue in debatable, the Commissioner can exercise his powers under section 263. For taking this view, support may be derived from the decision in CIT v. M. M. Khambhatwala 1992 198 ITR 144 (Guj.). 14. In the result, the appeal is decided in the terms indicated above.