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2012 (3) TMI 127 - AT - Income TaxConditions for Invoking order by Commissioner under Sec 263 - AO enquired for allowability of deduction u/s 80HHF in respect of interest income treated as business income and non-exclusion of expenses incurred in foreign currency under Explanation (c) and (j) below to Section 80HHF - Assessee gave detailed Explanation by writing letter - Held That:- AO on being satisfied allowed claim of assesee. The order of the AO could not be considered to be “erroneous” simply because two views are possible and the AO has taken as one view with which the ld. CIT does not agree, which cannot be treated as erroneous and prejudicial to the interests of the Revenue unless the view taken by the AO is found to be unsustainable in law.
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