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2022 (6) TMI 965 - ITAT KOLKATARevision u/s 263 - PCIT setting aside the assessment order on the issue of applicability of provisions of section 14A, examination of unsecured loan taken by the company,examination of TDS claim,examination of interest income earned, examination of depreciation claim on lease hold assets of the company,examination of expenses on corporate social responsibility incurred and directing the assessing officer for re-examination of the same - HELD THAT:- A perusal of above finding of the Ld. PCIT and also considering the judicial precedence referred therein, we find that neither any details were filed during the course of revisionary proceedings before the Ld. PCIT nor any details were filed before this Tribunal. There is no discussion on the alleged issues referred to show cause notice in the assessment order. All these facts indicate that the issues raised by the Ld. PCIT in the show cause notice giving rise to revisionary proceedings has not been examined by the Ld. AO and the same needs to be examined as per direction given by the Ld.PCIT in the impugned order. We, therefore, find no reason to interfere in the finding of the Ld. PCIT given in the impugned order passed u/s. 263 of the Act. Accordingly, all the grounds raised by the assessee are dismissed and revisionary proceedings u/s. 263 of the Act are held to be valid and hold that the Ld. PCIT has rightly invoked the jurisdiction and carried out the revisionary proceedings u/s. 263 - Decided against assessee.
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