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2020 (12) TMI 349 - AT - Income TaxRevision u/s.263 - provision for bad and doubtful debts u/s. 36(1)(viia) - PCIT had held that the assessee had claimed excess bad debts u/s.36(1)(vii) without reducing the opening credit balance (that is the amount of deduction allowed u/s.36(1)(viia) in the A.Y.2014-15) and the same was wrongly allowed by the Assessing Officer - HELD THAT:- As decided in own case [2020 (10) TMI 1011 - ITAT MUMBAI] assessee has filed detailed submissions before the Assessing Officer and the Assessing Officer has considered the submissions even though he has not discussed it in his order under Section 143(3) of the Act. The material submitted before us clearly indicate that assessee has made elaborate submissions on this issue and the Assessing Officer has satisfied himself that assessee is eligible to claim deduction under Section 36(1)(vii) and 36(1)(viia) of the Act and, therefore, in our considered view, ld. PCIT cannot form another view on the same issue in which the Assessing Officer has already satisfied himself and passed an order which clearly indicates that the Assessing Officer has verified and investigated the matter in detail. Therefore, even in this issue, the provisions of Section 263 of the Act cannot be invoked - Decided in favour of assessee.
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