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The direction to the Assessing Officer to compute deduction under Section 80 HHC in the order of the Commissioner of Income Tax is without any basis.

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Sec. 263 of Income Tax Act, 1961 – Revision – Tribunal vide common order allowed two appeals of the assessee filed against two separate orders of CIT under Section 263 of the IT Act, 1961 for the different assessment years saying that the Assessment Order cannot be called erroneous and prejudicial to the interest of the Revenue. High Court dismissed the appeals of the revenue holding that :– Section 263 of the Income Tax Act, 1961 is not intended to be invoked for every type of mistake or error committed by the Assessing Officer. It is only when an order is erroneous, it is attracted. Thus, the CIT erred in invoking the revisional powers under Section 263 of the Act, 1961 – CIT Vs. MADURA COATS LTD. [2020] 422 ITR 390 (MAD)

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