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2022 (4) TMI 1388 - AT - Income TaxRevision u/s 263 - Taxability being entrance fees received from the members treating the same to be a revenue receipt and taxable income of the Appellant - HELD THAT:- Since the assessee has been validated that from AY 2004-05, he has been receiving entrance membership, which has never been brought to tax as revenue receipts in the hands of the assessee, even on the principles of consistency, the Ld. Pr. Ld. CIT(A), in our view, has erred in revising the order passed u/s 263 of the Act, without bringing on record any material change in facts from the previous years. In the result, we are of the view that in light of the discussion above, Ld. Pr. CIT has erred in facts and in law, erred in initiating proceedings u/s 263 of the Act and setting aside the assessment order on the ground that it is erroneous and prejudicial to the interests of the Revenue. - Decided in favour of assessee.
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