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2018 (6) TMI 295 - AT - Income TaxRevision order passed u/s 263 for the order passed by the AO u/s 153A - “Deemed dividend” addition under Section 2(22)(e) - Held that:- The power to revise u/s 263 is where the order passed is erroneous and prejudicial to the interest of the Revenue. In the present case, the reassessment order passed u/s 153A, the same is neither erroneous nor prejudicial to the interest of the Revenue - thus order passed by the Ld. CIT cancelling assessment and directing the AO to frame the assessment afresh is bad in law followed by the decision in case of PR. CIT CENTRAL -1, DELHI VERSUS SHRI MAHESH KUMAR GUPTA [2016 (12) TMI 684 - DELHI HIGH COURT]. - Decided in favour of assessee.
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