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2018 (3) TMI 474 - AT - Income TaxRevision u/s 263 - addition u/s 68 towards share capital and share application money - Held that:- We hold that the order passed by the AO by adding a sum of ₹ 2.79 crores towards share capital cannot be termed as one which is prejudicial to the interests of the revenue warranting revisionary jurisdiction u/s 263. Notional loss representing changes in inventories of shares and securities - Held that:- We hold that the order passed by the AO by allowing the changes in inventories of finished goods, WIP and stock in trade as deduction and the same cannot be treated as MTM loss or notional loss and hence cannot be termed as erroneous in as much as it is prejudicial to the interests of the revenue, warranting revisionary jurisdiction u/s 263 of the Act in the facts and circumstances of the case. In view of the aforesaid findings with regard to both the issues of share capital and MTM losses, we hold that the revision order passed by the ld PCIT u/s 263 of the Act deserves to be quashed and is hereby quashed. Accordingly , the Grounds raised by the assessee are allowed. - Decided in favour of assessee.
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