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The impugned orders of learned CIT passed under s. 263 of the Act are unsustainable in law, hence, have to be quashed.

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Section 263 of the Income Tax Act, 1961 – Revision – AOs order of not bringing to tax interest earned by head office from Indian branch having been passed after considering the application of assessee and following decision of the Special Bench of the Tribunal, it was one of the possible views, hence could not be treated as erroneous and prejudicial to interests of revenue – JP Morgan Chase Bank NA vs. Deputy Commissioner of income tax[2020] 203 TTJ (Mumbai) 443

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