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2021 (9) TMI 953 - AT - Income TaxRevision u/s 263 by CIT - disallowance of 40% of the Diwali expenses and interest on late deposit of service tax - HELD THAT:- Observation of the ld. PCIT that there was no material to support the claim of the appellant and at AO accepted without verification is found to be contrary to the material available on record. AO is not expected to examine minutely the utilization of 150 wall clocks, 200 diaries and the calendars to whom they have been given and whether it is for business purpose or not, if so, what is the benefits derived thereof. PCIT has also not brought anything on record with regard to the prejudice or error in the assessment which led or indicate to loss of revenue by the way of bringing any cogent material on record. No material whatsoever has been brought on record by the Commissioner which shows that there was any discrepancy for falsity in submissions furnished by the assessee, the order of the Assessing Officer cannot be set aside for making deep enquiry in a heuristic way only on the presumption and assumption that something new may come out. - Decided in favour of assessee.
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