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2020 (10) TMI 602 - AT - Income TaxRevision u/s 263 - Assessee company claimed exemption u/s.10(20A) of the Act till A.Y. 2002-03 and Section 10(20A) was omitted by the Finance Act w.e.f. 01.04.2003 therefore, under income Tax Act, 1961, no exemption is available to the company - assessee declared income earned from the Govt. of Maharashtra as an agent - HELD THAT:- As decided in own case when the AO accepted the assessee is an agent and completed the assessment u/s 143(3) over the years, it means that the AO completed the assessment with one particular view, whereas Pr. CIT intends to correct the above view and presumed that the case of assessee falls under Article 289(1) and come to a conclusion that assessee is not comes under Article 289 and subjected to tax under Income Tax Act, therefore, in our view, this is another view in the case of assessee.- Pr. CIT cannot invoke the provision of section 263 of the Act when two views are possible as held in the case of CIT vrs. Max India [2007 (11) TMI 12 - SUPREME COURT]. - Decided in favour of assessee.
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