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2017 (10) TMI 1100 - HC - Income TaxRevision u/s 263 - AO upheld the assessee’s contention with regard to applicability of Section 10B to its unit - Section 263 was invoked primarily on the ground that the approval did not conform to the CBDT’s circular dated 09.03.2009 (F.No.178/19/2008) - Held that:- The invocation of Section 263 in the opinion of this Court cannot be faulted. As to whether in fact there was no necessity for a further ratification, in the light of the appellant’s contention that a general or a specific circular, which delegated the powers of the Board of Approvals, applied after the issuance of the 09.03.2009 circular, is however kept open for consideration. In case such contention is urged by the appellant before the Income Tax authorities, the same shall be considered on its own merits.
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