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2021 (1) TMI 990 - AT - Income TaxRevision u/s 263 - provision for expenses disallowable or it is provision for contingent liability - HELD THAT:- Finding of the CIT-2, Pune that the provision for expenses is contingent liability is not based on any material, it is mere ipse dixit - impugned order does not contain an allegation by the ld. Pr. Commissioner of Income Tax-2, Pune that the Assessing Officer had not enquired into this issue during the course of assessment proceedings. Thus, it is clear that it is not even case of learned CIT that AO had not enquired into this case. Therefore, the case even does not fall within ambit of Explanation 2 to sub-section (1) of section 263 of the Act inserted by Finance Act, 2015 w.e.f. 1.6.15. Considering all the above facts, it cannot be said that the assessment order is erroneous causing consequence prejudice to the interests of the revenue. - Decided in favour of assessee.
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