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2022 (8) TMI 1359 - AT - Income TaxRevision u/s 263 - As per PCIT AO failed to verify the appellants claims related current repairs and maintenance of machinery, current repairs and maintenance of building and deduction of the interest out of the business income of the assessee - PCIT further observed that the copy of ledger account filed by the assessee shows that substantial amounts have been reflected in the account which do not seem to be in the nature of repair and maintenance - HELD THAT:- In the present case, the assessee’s claimed expenses under the head current repairs and maintenance of machinery, current repairs and maintenance of building and interest claimed on creditors was accounted for in the ledger, produced for verification during the course of scrutiny assessment proceedings u/s 143(3) and 154 before the AO and duly stands verified to his satisfaction. PCIT has merely stated that the AO has failed to make necessary enquiry and investigation, however he has not specified the particular head of the account or the expense with the support of the corroborative evidences being brought on record to hold that how the assessment order was to be erroneous and prejudicial to the interest of the revenue. In our view, such vague observation made by the PCIT, merely doubting the assessment proceedings cannot hold the assessment order erroneous and prejudicial to the interest of the Revenue and that to base on the audit objection in particular. Assessing Authority has made enquiry about the expenses claimed by the appellant assessee in respect of current repairs and maintenance of machinery, current repairs and maintenance of building and interest claimed during the course of assessment proceedings as well as 154 proceedings. The AO was satisfied from the reply of the assessee and after consideration of the reply, the AO has filed the proceedings u/s 154. The observation of the PCIT that no enquiries or verification were made, is factually incorrect - Appeal of the assessee is allowed.
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