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2009 (11) TMI 481 - HC - Income TaxRevenue expenditure - Expenses on account of strategic management consultancy fee - revision u/s 263 - erroneous order - in view of ITAT the expenses on account of strategic management consultancy fee claimed as revenue expenditure is correct - A possible view of the matter thus was taken by the AO accepting the claim of the assessee on this issue while completing the assessment u/s 143(3) and we, therefore, agree with the contention of the ld Counsel of the assessee raised before us that it was not permissible for the ld. CIT u/s 263 to substitute such possible view taken by the AO with his own view merely on the basis of some comments made in the audit report which otherwise also were not conclusive in this regard. - Held that: There is no merit in the appeal - revenue appeal dismissed
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